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Income Taxes
6 Months Ended
Oct. 30, 2015
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes
During the second quarter of fiscal year 2016, the Company recorded a $442 million tax charge primarily associated with the Internal Reorganization, as defined below, of the ownership of certain legacy Covidien businesses. This charge was recorded within provision for income taxes in the condensed consolidated statements of income.
The Company’s effective tax rates for the three and six months ended October 30, 2015 were 52.0 percent and 33.8 percent, respectively, compared to 19.0 percent and 19.3 percent for the three and six months ended October 24, 2014, respectively. The change in the Company’s effective tax rate for the three and six months ended October 30, 2015 was primarily due to the impact of certain tax adjustments of $442 million, which largely relates to U.S. income tax expense resulting from our completion of an internal reorganization of the ownership of certain legacy Covidien businesses that reduced the cash and investments held by our U.S.-controlled non-U.S. subsidiaries (the Internal Reorganization). The change was also attributable to the impact of special charges, restructuring charges, net, acquisition-related items, the other effects of the acquisition of Covidien, and year over year changes in operational results by jurisdiction.
During the six months ended October 30, 2015, the Company's gross unrecognized tax benefits decreased from $2.860 billion to $2.602 billion. In addition, the Company has accrued gross interest and penalties of $588 million as of October 30, 2015. If all of the Company’s unrecognized tax benefits were recognized, approximately $2.022 billion would impact the Company’s effective tax rate. The Company has recorded $5 million of gross unrecognized tax benefits as a current liability and $2.597 billion as a long-term liability.
The Company will continue to recognize interest and penalties related to income tax matters within provision for income taxes in the condensed consolidated statements of income and record the liability within accrued income taxes or long-term accrued income taxes in the condensed consolidated balance sheets, as appropriate.
See Note 16 to the condensed consolidated financial statements for additional information regarding the status of current tax audits and proceedings.