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Income Taxes
 9 Months Ended
Jun. 30, 2022
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
In calculating the provision for income taxes, the Company uses an estimate of the annual effective tax rate based upon the facts and circumstances known at each interim period. On a quarterly basis, the actual effective tax rate is adjusted, as appropriate, based upon changed facts and circumstances, if any, as compared to those forecasted at the beginning of the fiscal year and each interim period thereafter.

The statutory tax rate in Ireland is being used as a comparison since the Company is domiciled in Ireland. For the three months ended June 30, 2022, the Company's effective tax rate for continuing operations was 12.1% and was lower than the statutory tax rate of 12.5% primarily due to the income tax effects of mark-to-market adjustments and the benefits of continuing global tax planning initiatives, partially offset by the establishment of a deferred tax liability on the outside basis difference of the Company's investment in certain subsidiaries as a result of the planned divestitures and tax rate differentials. For the nine months ended June 30, 2022, the Company's effective tax rate for continuing operations was 17.2% and was higher than the statutory tax rate of 12.5% primarily due to the tax impact of an impairment charge, the establishment of a deferred tax liability on the outside basis difference of the Company's investment in certain subsidiaries as a result of the planned divestitures and tax rate differentials, partially offset by the income tax effects of mark-to-market adjustments and the benefits of continuing global tax planning initiatives. For the three months ended June 30, 2021, the Company's effective tax rate for continuing operations was 14.0% and was higher than the statutory tax rate of 12.5% primarily due to the income tax effects of mark-to-market adjustments and tax rate differentials, partially offset by the benefits of continuing global tax planning initiatives. For the nine months ended June 30, 2021, the Company's effective tax rate for continuing operations was 20.9% and was higher than the statutory tax rate of 12.5% primarily due to valuation allowance adjustments, the income tax effects of mark-to-market adjustments and tax rate differentials, partially offset by the benefits of continuing global tax planning initiatives.

Valuation Allowance

The Company reviews the realizability of its deferred tax assets on a quarterly basis, or whenever events or changes in circumstances indicate that a review is required. In determining the requirement for a valuation allowance, the historical and projected financial results of the legal entity or consolidated group recording the net deferred tax asset are considered, along with any other positive or negative evidence. Since future financial results may differ from previous estimates, periodic adjustments to the Company’s valuation allowances may be necessary.

In the second quarter of fiscal 2021, due to changes in forecasted taxable income, the Company recorded a discrete tax charge of $105 million related to valuation allowances on certain Mexico deferred tax assets now considered unrealizable.

Uncertain Tax Positions

At September 30, 2021, the Company had gross tax-effected unrecognized tax benefits of $2,726 million, of which $2,268 million, if recognized, would impact the effective tax rate. Total net accrued interest at September 30, 2021 was approximately $252 million (net of tax benefit). Total net accrued interest during the nine months ended June 30, 2022 and 2021 was approximately $40 million (net of tax benefit) and approximately $37 million (net of tax benefit), respectively. The Company recognizes interest and penalties related to unrecognized tax benefits as a component of income tax expense.
In the U.S., fiscal years 2017 through 2018 are currently under exam by the Internal Revenue Service (“IRS”) for certain legal entities. Additionally, the Company is currently under exam in the following major non-U.S. jurisdictions for continuing operations:
Tax JurisdictionTax Years Covered
Belgium
2015 - 2021
Germany
2007 - 2018
Luxembourg
2017 - 2018
Mexico
2015 - 2021
United Kingdom
2014 - 2015, 2017 - 2018

Subsequent to June 30, 2022, the statute of limitations for certain tax years expired, which will result in an approximately $300 million benefit to income tax expense in the fourth quarter of 2022. It is reasonably possible that additional tax examinations and/or tax litigation will conclude within the next twelve months, which could have a material impact on tax expense. Based upon the circumstances surrounding these examinations, the impact is not currently quantifiable.

Other Tax Matters

During the three months ended June 30, 2022, the Company recorded net mark-to-market losses of $126 million which generated a $33 million tax benefit, restructuring and impairment costs of $121 million which generated a $15 million tax benefit, transaction costs of $9 million which generated a $1 million tax benefit and a deferred tax liability on the outside basis difference of the Company’s investment in certain subsidiaries which resulted in a tax charge of $8 million.

During the nine months ended June 30, 2022, the Company recorded net mark-to-market losses of $158 million which generated a $40 million tax benefit, restructuring and impairment costs of $554 million which generated a $29 million tax benefit, transaction costs of $9 million which generated a $1 million tax benefit and a deferred tax liability on the outside basis difference of the Company’s investment in certain subsidiaries which resulted in a tax charge of $21 million.

During the three months ended June 30, 2021, the Company recorded net mark-to-market gains of $66 million which generated tax expense of $17 million and $79 million of restructuring and impairment costs which generated a $15 million tax benefit.

During the nine months ended June 30, 2021, the Company recorded net mark-to-market gains of $296 million which generated tax expense of $75 million and $175 million of restructuring and impairment costs which generated a $30 million tax benefit.

Tax expenses and benefits for the above transactions reflect the Company’s current tax positions in the impacted jurisdictions. Refer to Note 17, “Significant Restructuring and Impairment Costs,” and Note 18, “Impairment of Long-Lived Assets,” of the notes to the consolidated financial statements for additional information.

Impacts of Tax Legislation
During the nine months ended June 30, 2022 and 2021, tax legislation was adopted in various jurisdictions. These law changes did not have a material impact on the Company's consolidated financial statements.