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Income Taxes | 6 Months Ended
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Jan. 31, 2018
Income Tax Disclosure [Abstract] |
Income Taxes | NOTE 8 – Income Taxes The Company applies the provisions of the accounting standard for uncertain tax positions to its income taxes. For benefits to be realized, a tax position must be more likely than not to be sustained upon examination. The amount recognized is measured as the largest amount of benefit that is greater than 50% likely of being realized upon ultimate settlement. As of January 31, 2018, the gross amounts of the Company’s liabilities for unrecognized tax benefits of $27.1 million, including interest and penalties, were classified as long-term income taxes payable in the accompanying consolidated balance sheets. Over the next twelve months, the Company’s existing positions will continue to generate an increase in liabilities for unrecognized tax benefits, as well as a likely decrease in liabilities as a result of the lapse of the applicable statute of limitations and the conclusion of income tax audits. The expected decrease in liabilities relating to unrecognized tax benefits will have a positive effect on the Company’s consolidated results of operations and financial position when realized. The Company recognizes interest and penalties related to uncertain tax positions in income tax expense. The Company files income tax returns in the U.S. federal jurisdiction, various states and foreign jurisdictions. The Company is currently under examination by certain taxing authorities in the U.S. for fiscal years between 2012 and 2016. At this time, the Company does not believe that the outcome of any examination will have a material impact on the Company’s consolidated results of operations and financial position. The Company’s effective income tax rates were 28.5% and 34.0% for the three months ended January 31, 2018 and 2017, respectively, and 30.1% and (15.2)% for the six months ended January 31, 2018 and 2017, respectively. The tax rates in the prior year were impacted primarily from the result of recognizing excess tax benefits from the exercise of employee stock options of $2.6 million and $1.3 million for the three months ended January 31, 2018 and 2017, respectively, and $6.4 million and $102.7 million for the six months ended January 31, 2018 and 2017, respectively. The effective tax rate for the three months ended January 31, 2018 was computed based on a reduced blended U.S. federal corporate tax rate of 26.9% for the fiscal year ending July 31, 2018, and included the effects of the Tax Cuts and Jobs Act. On December 22, 2017, the U.S. government enacted comprehensive tax legislation commonly referred to as the Tax Cuts and Jobs Act (“Tax Reform” or “Tax Act”). Tax Reform makes broad and complex changes to the U.S. tax code, including, but not limited to (i) reducing the U.S. federal corporate tax rate from 35.0% to 21.0%; (ii) requiring companies to pay a one-time transition tax on certain unrepatriated earnings of foreign subsidiaries (“Transition Tax”); (iii) generally eliminating U.S. federal income taxes on dividends from foreign subsidiaries; (iv) creating a new provision designed to tax global intangible low-taxed income (“GILTI”) which allows for the possibility of using foreign tax credits (“FTCs”) and a deduction of up to 50.0% to offset the income tax liability (subject to some limitations); (v) allowing for full expensing of qualified property through bonus depreciation; and (vi) creating limitations on the deductibility of certain executive compensation. The SEC staff issued Staff Accounting Bulletin No. 118 (“SAB 118”), which provides guidance on accounting for the tax effects of Tax Reform. SAB 118 provides a measurement period that should not extend beyond one year from enactment for companies to complete the accounting under ASC 740, Income Taxes. In accordance with SAB 118, a company must reflect the income tax effects of those aspects of Tax Reform for which the accounting under ASC 740 is complete in the financial statements. To the extent that a company’s accounting for certain income tax effects of Tax Reform is incomplete, but a reasonable estimate is able to be made, the company must record a provisional estimate in the financial statements. If a company cannot determine a provisional estimate to be included in the financial statements, it should continue to apply ASC 740 on the basis of the tax laws that were in effect immediately before the enactment of Tax Reform. Because the Company is a fiscal year taxpayer, under IRC Section 15, the blended tax rate the Company used to obtain the benefit of reduced tax rate was 26.9% for the fiscal year ending July 31, 2018. Upon enactment, the Company remeasured its deferred tax balances to reflect the reduced U.S. federal tax rate, which resulted in a tax benefit of $0.6 million. The Company also recorded a provisional tax liability for the Transition Tax of $12.0 million, which after accounting for certain foreign tax credits made available by incurring the Transition Tax, resulted in recording an expense of $10.6 million during the six months ended January 31, 2018. The Company has not completed its accounting for the tax effects of the enactment of the Tax Act. Specifically, the amount recorded for the Transition Tax is a provisional amount based on the Company’s estimates. The Company expects to complete the accounting for these impacts of the Tax Act in the fiscal quarter ending January 31, 2019 as it finalizes its cumulative earnings and profits of its foreign subsidiaries and receives additional guidance from the IRS pertaining to the Tax Act. The impacts of additional guidance and changes in estimates related to the effects of the Tax Act, if any, will be recorded in the period the additional guidance or information is available. The Company re-measured deferred tax assets and liabilities based on the U.S, statutory income tax rate. However, the Company is still analyzing certain aspects of the Tax Act and refining its calculation, which could potentially affect the measurement of these balances or potentially give rise to new deferred tax amounts. Because the GILTI is not applicable until fiscal years after August 1, 2018, no provisional adjustments were recorded. The Tax Act creates a new requirement that GILTI earned by controlled foreign corporations (“CFCs”) must be included currently in the gross income of the CFCs’ U.S. shareholders. GILTI is the excess of the shareholder’s “net CFC tested income” over the net deemed tangible income return which is currently defined as the excess of (i) 10.0% of the aggregate of the U.S. shareholder’s pro rata share of the qualified business asset investment of each CFC over (ii) the amount of certain interest expense taken into account in the determination of net CFC-tested income. As part of Tax Reform, the Company incurred U.S. tax on substantially all of the earnings of its foreign subsidiaries as part of the Transition Tax. This tax increased the Company’s previously taxed earnings and will allow for the repatriation of the majority of its foreign earnings without any U.S. federal tax. However, any repatriation of its foreign earnings could still have substantial impacts on withholding taxes, state taxes or other income taxes that might be incurred from the potential reversal of the Company’s overall outside basis difference. Accordingly, the Company is reevaluating its previous investment assertions regarding the excess of the amount for financial reporting over the tax basis as a result of Tax Reform. In January 2018, the Company repatriated $51.7 million of earnings that will be considered previously taxed, from the U.K. to the U.S. and concluded that there were no material additional taxes incurred. The Company also expects to repatriate an additional $42.2 million of earnings on or about February 28, 2018, that will be considered previously taxed, from the U.K. to the U.S. and concluded that there were no material additional taxes incurred. As part of its provisional estimate under SAB 118, the Company has not finalized any additional plans to repatriate previously taxed earnings, but may choose to repatriate additional previously taxed earnings, to the extent of its international operations’ cash capacities, in the future. However, the Company’s cash flow needs in the U.S. have not changed significantly for reasons other than those caused by Tax Reform and intends to continue to reinvest its foreign undistributed earnings to expand its international footprint. Accordingly, the Company did not provide any taxes other than the Transition Tax on such earnings as of January 31, 2018.

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- Definition The entire disclosure for income taxes. Disclosures may include net deferred tax liability or asset recognized in an enterprise's statement of financial position, net change during the year in the total valuation allowance, approximate tax effect of each type of temporary difference and carryforward that gives rise to a significant portion of deferred tax liabilities and deferred tax assets, utilization of a tax carryback, and tax uncertainties information. + References Reference 1: http://www.xbrl.org/2003/role/presentationRef -Publisher FASB -Name Accounting Standards Codification -Topic 740 -URI http://asc.fasb.org/topic&trid=2144680 + Details
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