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Income Taxes | 12 Months Ended
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Jul. 31, 2024
Income Tax Disclosure [Abstract] |
Income Taxes | Income Taxes Income before taxes consisted of the following:
|  | Year Ended July 31,
(In thousands) |  | 2024 |  | 2023 |  | 2022
U.S. |  | $ | 1,593,381 |  |  | $ | 1,437,126 |  |  | $ | 1,241,177 |
International |  | 121,220 |  |  | 117,202 |  |  | 99,777 |
Total income before taxes |  | $ | 1,714,601 |  |  | $ | 1,554,328 |  |  | $ | 1,340,954 |
Income tax expense (benefit) from continuing operations consisted of the following:
|  | Year Ended July 31,
(In thousands) |  | 2024 |  | 2023 |  | 2022
Federal: |  |  |  |  |  |
Current |  | $ | 271,820 |  |  | $ | 243,253 |  |  | $ | 179,840 |
Deferred |  | (1,174) |  |  | (4,642) |  |  | 14,115 |
|  | 270,646 |  |  | 238,611 |  |  | 193,955 |
State: |  |  |  |  |  |
Current |  | 49,539 |  |  | 47,507 |  |  | 33,078 |
Deferred |  | (1,611) |  |  | 813 |  |  | 1,689 |
|  | 47,928 |  |  | 48,320 |  |  | 34,767 |
International: |  |  |  |  |  |
Current |  | 34,179 |  |  | 26,150 |  |  | 23,247 |
Deferred |  | (499) |  |  | 3,506 |  |  | (1,145) |
|  | 33,680 |  |  | 29,656 |  |  | 22,102 |
Income tax expense |  | $ | 352,254 |  |  | $ | 316,587 |  |  | $ | 250,824 |
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) |  | 2024 |  | 2023 |  | 2022
Federal statutory rate |  | 21.0 | % |  | 21.0 | % |  | 21.0 | %
State income taxes, net of federal income tax benefit |  | 2.4 | % |  | 2.0 | % |  | 1.3 | %
International rate differential |  | 0.1 | % |  | (0.3) | % |  | (0.5) | %
Compensation and fringe benefits |  | (0.7) | % |  | (1.0) | % |  | (0.6) | %
FDII and/or GILTI |  | (2.8) | % |  | (2.8) | % |  | (2.8) | %
Federal return to provision adjustment |  | — | % |  | (0.1) | % |  | 0.6 | %
Federal amended return adjustment |  | — | % |  | — | % |  | (1.3) | %
Other differences |  | 0.5 | % |  | 1.6 | % |  | 1.0 | %
Effective tax rate |  | 20.5 | % |  | 20.4 | % |  | 18.7 | %
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) |  | 2024 |  | 2023 |  |
Deferred tax assets: |  |  |  |  |  |
Allowance for credit loss |  | $ | 2,483 |  |  | $ | 1,505 |  |  |
Accrued compensation and benefits |  | 22,957 |  |  | 17,008 |  |  |
Operating lease liabilities |  | 24,897 |  |  | 22,891 |  |  |
Accrued other |  | 5,528 |  |  | 2,212 |  |  |
Deferred revenue |  | 5,544 |  |  | 5,349 |  |  |
Losses carried forward/interest disallowance |  | 48,599 |  |  | 41,589 |  |  |
Federal tax benefit |  | 12,821 |  |  | 14,798 |  |  |
Total gross deferred tax assets |  | 122,829 |  |  | 105,352 |  |  |
Less: Valuation allowance |  | (47,377) |  |  | (40,346) |  |  |
Net deferred tax assets |  | 75,452 |  |  | 65,006 |  |  |
Deferred tax liabilities: |  |  |  |  |  |
Vehicle pooling costs |  | (27,716) |  |  | (25,808) |  |  |
Property and equipment |  | (74,741) |  |  | (70,086) |  |  |
Operating lease right-of-use assets |  | (24,612) |  |  | (23,169) |  |  |
Other prepaids |  | (2,339) |  |  | (2,548) |  |  |
Intangibles and goodwill |  | (38,279) |  |  | (33,150) |  |  |
Total gross deferred tax liabilities |  | (167,687) |  |  | (154,761) |  |  |
Net deferred tax liabilities |  | $ | (92,235) |  |  | $ | (89,755) |  |  |
On December 22, 2017 legislation, commonly referred to as the Tax Cuts and Jobs Act (the “Act”), was enacted. 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 Company has no GILTI inclusion for the fiscal year ended July 31, 2024. 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 had a material impact to the effective income tax rate and income tax expense for the fiscal year ended July 31, 2024. The Company’s effective income tax rates were 20.5%, 20.4%, and 18.7% for fiscal 2024, 2023 and 2022, respectively. The Company’s U.S. federal statutory tax rate for fiscal years 2024, 2023, and 2022 was 21.0%. The effective tax rate for the fiscal year ended July 31, 2024 was favorably impacted by $0.8 million of tax adjustments made in connection with finalizing the Company’s fiscal year 2023 tax return, and favorably impacted by a $47.7 million FDII deduction in the current year. The effective tax rate for the fiscal year ended July 31, 2023 was favorably impacted by $1.5 million of tax adjustments made in connection with finalizing the Company’s fiscal year 2022 tax return, and favorably impacted by a $42.6 million FDII deduction. The effective tax rate for the fiscal year ended July 31, 2022 was unfavorably impacted by a $8.2 million of tax adjustments made in connection with finalizing the Company’s fiscal year 2021 tax return, favorably impacted by a $17.0 million of tax items related to amending previously filed income tax returns, and favorably impacted by a $37.2 million FDII deduction. The effective tax rates were also impacted by the recognition of excess tax benefits from the exercise of employee stock-based compensation of $14.8 million, $21.0 million, and $14.4 million, for the fiscal years ended July 31, 2024, 2023, and 2022, respectively. 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. During fiscal year 2024, the Company recorded a $7.0 million increase in valuation allowances primarily due to additional operating losses and interest disallowance carryforward generated in foreign jurisdictions unlikely to be realized. As of July 31, 2024 and 2023, the Company had foreign operating losses and interest disallowance carryforward of $48.6 million and $41.6 million (tax effected), respectively. The foreign operating losses, subject to certain limitations, usually can be carried forward indefinitely. However, these losses are subject to valuation allowance based on realizability. The valuation allowance for the fiscal year ended July 31, 2024 and 2023 was $47.4 million and $40.3 million, respectively, which are primarily related to operating losses in certain foreign jurisdictions. The following table summarizes the activities related to the Company’s unrecognized tax benefits resulting from uncertain tax positions.
|  | July 31,
(In thousands) |  | 2024 |  | 2023 |  | 2022
Beginning balance |  | $ | 57,445 |  |  | $ | 55,754 |  |  | $ | 47,061 |
Increases related to current year tax positions |  | 2,955 |  |  | 10,006 |  |  | 14,809 |
Prior year tax positions: |  |  |  |  |  |
Increases recognized during the period |  | 11 |  |  | 1,388 |  |  | 1,393 |
Decreases recognized during the period |  | (7,070) |  |  | (7,623) |  |  | (2,163) |
Cash settlements during the period |  | (6,062) |  |  | (403) |  |  | (3,524) |
Lapse of statute of limitations |  | (1,554) |  |  | (1,677) |  |  | (1,822) |
Ending balance |  | $ | 45,725 |  |  | $ | 57,445 |  |  | $ | 55,754 |
As of July 31, 2024 and 2023, 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 $36.1 million and $45.3 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, 2024, 2023 and 2022, the Company had accrued interest and penalties related to unrecognized tax benefits of $13.8 million, $11.7 million and $8.9 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 2018 and 2022. 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. As of July 31, 2024, the Company has undistributed earnings of approximately $500.8 million generated by its foreign subsidiaries. As the Company determined these undistributed foreign earnings along with any additional outside basis differences were indefinitely reinvested as of July 31, 2024, no deferred tax was therefore provided. The Company believes it is not practicable 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. However, the Company would not anticipate any significant tax liability associated with the repatriation of the undistributed earnings.

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