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Income Taxes
 12 Months Ended
Jul. 31, 2021
Income Tax Disclosure [Abstract]  
Income Taxes
NOTE 12 — Income Taxes

Income before taxes consisted of the following:
Year Ended July 31,
(In thousands)202120202019
U.S.$1,022,134 $740,171 $634,874 
International99,712 60,668 70,077 
Total income before taxes$1,121,846 $800,839 $704,951 

Income tax expense (benefit) from continuing operations consisted of the following:
Year Ended July 31,
(In thousands)202120202019
Federal:   
Current$135,216 $53,942 $59,848 
Deferred(4,259)21,019 27,779 
 130,957 74,961 87,627 
State:   
Current34,302 12,095 12,720 
Deferred(3,489)565 702 
 30,813 12,660 13,422 
International:   
Current23,575 13,333 12,508 
Deferred6 (22)(299)
 23,581 13,311 12,209 
Income tax expense$185,351 $100,932 $113,258 

A reconciliation of the expected U.S. statutory tax rate to the actual effective income tax rate is as follows:
Year Ended July 31,
(In thousands)202120202019
Federal statutory rate21.0 %21.0 %21.0 %
State income taxes, net of federal income tax benefit1.5 %1.6 %1.4 %
International rate differential(0.5)%0.1 %0.3 %
Compensation and fringe benefits (1)
(1.9)%(11.2)%(6.4)%
FDII, GILTI, and transition tax(3.1)%(0.3)%(0.7)%
Federal return to provision adjustment(1.8)%— %— %
Other differences1.3 %1.4 %0.5 %
Effective tax rate16.5 %12.6 %16.1 %
(1)Included in the compensation and fringe benefits rate reconciliation is the impact of the Company’s adoption of ASU No. 2016-09, Improvements to Employee Share-Based Payment Accounting. Under this standard, all excess tax benefits and tax deficiencies related to exercises of stock options are recognized as income tax expense or benefit in the income statement as discrete items in the reporting period in which they occur.
The tax effects of temporary differences that give rise to significant portions of the deferred tax assets (liabilities) are presented below:
July 31,
(In thousands)20212020
Deferred tax assets:  
Allowance for credit loss$942 $1,141 
Accrued compensation and benefits15,541 13,217 
State taxes— 460 
Operating lease liabilities25,176 — 
Accrued other4,551 4,763 
Deferred revenue4,239 1,950 
Losses carried forward24,384 15,092 
Federal tax benefit12,242 9,872 
Total gross deferred tax assets87,075 46,495 
Less: Valuation allowance(24,987)(15,429)
Net deferred tax assets62,088 31,066 
Deferred tax liabilities:  
Vehicle pooling costs(20,241)(15,291)
Property and equipment(55,047)(62,123)
Operating lease right-of-use assets(25,253)— 
Other prepaids(461)(1,411)
Intangibles and goodwill(24,602)(23,714)
Total gross deferred tax liabilities(125,604)(102,539)
Net deferred tax liabilities$(63,516)$(71,473)

On December 22, 2017 legislation, commonly referred to as the Tax Cuts and Jobs Act (the “Act”), was enacted. The Act included a one-time tax on accumulated unremitted earnings of the Company’s foreign subsidiaries (“Transition Tax”). The Act contains Global Intangible Low-Taxed Income (“GILTI”) provisions, which first impacted the Company in fiscal year 2019. The GILTI provisions effectively subject income earned by the Company's foreign subsidiaries to current U.S. tax at a rate of 10.5%, less foreign tax credits. Under U.S. GAAP, the Company can make an accounting policy election to either recognize deferred taxes for temporary differences expected to impact GILTI in future years or provide for tax expense related to GILTI in the year the tax is incurred as a period expense. The Company has elected to treat tax generated by GILTI provisions as a period expense.

The Act also includes a favorable tax treatment for certain Foreign Derived Intangible Income (“FDII”), effective for the Company starting August 1, 2018. The Company’s estimate for FDII did have a material impact to the effective income tax rate and income tax expense for the fiscal year ended July 31, 2021.

As of July 31, 2021 and 2020, the Company had foreign operating losses and a U.S. federal tax credit carryforward of $24.4 million and $15.1 million, respectively. The foreign operating losses, subject to certain limitations, usually can be carried forward indefinitely. The U.S. federal related tax credit, if not used, would start to expire after 2026.

The Company’s ability to realize deferred tax assets is dependent on its ability to generate future taxable income. Accordingly, the Company has established a valuation allowance in taxable jurisdictions where the utilization of the tax assets is uncertain. Additional timing differences or future tax losses may occur which could warrant a need for establishing additional valuation allowances against certain deferred tax assets. The valuation allowance for the years ended July 31, 2021 and 2020 was $25.0 million and $15.4 million, respectively. The valuation allowance for deferred tax assets primarily related to operating losses in certain international jurisdictions and certain tax credits that are unlikely to be realized.
The following table summarizes the activities related to the Company’s unrecognized tax benefits resulting from uncertain tax positions:
July 31,
(In thousands)202120202019
Beginning balance$36,123 $27,537 $21,322 
Increases related to current year tax positions13,122 8,196 6,588 
Prior year tax positions:   
Increases recognized during the period8,782 6,390 800 
Decreases recognized during the period(5,749)(1,603)(305)
Cash settlements during the period(3,261)(1,182)(534)
Lapse of statute of limitations(1,956)(3,215)(334)
Ending balance$47,061 $36,123 $27,537 

As of July 31, 2021 and 2020, if recognized, the portion of liabilities for unrecognized tax benefits resulting from uncertain tax positions that would favorably affect the Company’s effective tax rate was $37.8 million and $29.0 million, respectively. It is possible that the amount of unrecognized tax benefits will change in the next twelve months, due to tax legislation updates or future audit outcomes; however, an estimate of the range of the possible change cannot be made at this time.

The Company recognizes interest and penalties related to income tax matters in income tax expense. As of July 31, 2021, 2020 and 2019, the Company had accrued interest and penalties related to unrecognized tax benefits of $7.2 million, $8.9 million and $7.6 million, respectively.

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 2014 and 2018. 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 Act significantly lowered the additional federal income tax upon the repatriation of undistributed earnings generated by our foreign subsidiaries. As the Company determined these undistributed foreign earnings along with any additional outside basis differences were indefinitely reinvested as of July 31, 2021, no deferred tax was therefore provided. Although the Company would not anticipate any significant tax liability associated with the repatriation of the undistributed earnings, which were $234.7 million as of July 31, 2021, nevertheless, it is not practical to estimate the amount of deferred tax liability related to the entire outside basis differences due to the complexity of the calculation and the uncertainty regarding assumptions necessary to compute the tax.
The Company’s effective income tax rates were 16.5%, 12.6%, and 16.1% for fiscal 2021, 2020 and 2019, respectively. The Company’s U.S. federal statutory tax rate for fiscal years 2021, 2020 and 2019 was 21.0%. The effective tax rate for fiscal year ending July 31, 2021 was favorably impacted by $19.8 million of discrete tax adjustments made in connection with finalizing the Company’s fiscal year 2020 tax return. The effective tax rate for fiscal year ending July 31, 2020 was negatively impacted by $1.7 million of discrete tax items related to amending previously filed income tax returns. The effective tax rate for the fiscal year ending July 31, 2019, was favorably impacted by $10.2 million of discrete tax items related to amending previously filed income tax returns. The effective tax rates were also impacted by the recognition of excess tax benefits from the exercise of employee stock-based compensation of $29.8 million, $92.5 million, and $46.1 million, for fiscal years ended July 31, 2021, 2020 and 2019, respectively.