Note 12—Income Taxes

The effective income tax rates were 33% and 29% for the three and nine months ended June 30, 2014, respectively, and 33% and 31% for the three and nine months ended June 30, 2013, respectively. The effective tax rate for the nine months ended June 30, 2014 differs from the effective tax rate in the same period in fiscal 2013 primarily due to:


•	a $245 million tax benefit related to the deduction for U.S. domestic production activities, of which $189 million related to prior fiscal years, as a result of the completion of a study in the second quarter of fiscal 2014; and


•	the absence of a $76 million tax benefit recognized in the first quarter of fiscal 2013, as a result of new guidance issued by the state of California regarding apportionment rules for years prior to fiscal 2012.

During the three and nine months ended June 30, 2014, the Company's gross unrecognized tax benefits increased by $43 million and $223 million, respectively, $42 million and $219 million of which, respectively, would favorably impact the effective income tax rate if recognized. The increase in gross unrecognized tax benefits is primarily due to potential audit exposure related to various tax positions across several jurisdictions. During the three and nine months ended June 30, 2014, the Company accrued $4 million and $8 million of interest, respectively, and released $1 million and $2 million of penalties, respectively, related to uncertain tax positions.