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Income Taxes
 12 Months Ended
Jun. 30, 2023
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
Income before income taxes for the years ended June 30, 2023, 2022 and 2021, was taxed under the following jurisdictions (in thousands):
202320222021
U.S.$128,589 $(85,919)$71,867 
Non-U.S.973,075 1,046,402 811,795 
Income before income taxes$1,101,664 $960,483 $883,662 
The provision for income taxes is presented below (in thousands):
202320222021
Current:Federal$36,631 $4,376 $(115,109)
State14,142 10,700 9,041 
Non-U.S.198,767 177,788 531,812 
249,540 192,864 425,744 
Deferred: Federal(21,721)(12,612)(22,791)
State(2,389)(2,773)(4,205)
Non-U.S.(21,322)3,567 10,409 
(45,432)(11,818)(16,587)
Provision for income taxes$204,108 $181,046 $409,157 
The provision for income taxes differs from the amount of income tax determined by applying the applicable U.S. federal income tax rate of 21% for the years ended June 30, 2023, 2022 and 2021, to pretax income as a result of the following (in thousands):
202320222021
Taxes computed at statutory U.S. rate$231,349 $201,701 $185,569 
Increase (decrease) in income taxes resulting from:
State income taxes, net of U.S. tax benefit9,448 5,703 4,836 
Research and development credit(21,481)(17,517)(20,257)
Change in valuation allowance(5,007)858 (3,785)
Effect of non-U.S. tax rates(3,982)(4,384)(12,130)
Foreign tax credits(3,988)(2,299)(7,210)
Stock-based compensation expense(6,282)(11,294)(4,498)
Uncertain tax position— — 248,773 
Other4,051 8,278 17,859 
Provision for income taxes$204,108 $181,046 $409,157 
We reported net deferred tax assets and liabilities in our consolidated balance sheets at June 30, 2023 and June 30, 2022, as follows (in thousands):
20232022
Non-current deferred tax asset$132,974 $79,746 
Non-current deferred tax liability(90,650)(9,714)
Net deferred tax asset$42,324 $70,032 
The components of our deferred tax assets and liabilities at June 30, 2023 and June 30, 2022, are as follows (in thousands):
20232022
Deferred tax assets:
Employee liabilities$34,314 $28,556 
Tax credit carry overs6,051 7,723 
Inventories13,212 10,570 
Provision for warranties5,348 4,814 
Provision for doubtful debts6,103 5,096 
Net operating loss carryforwards22,387 27,490 
Capital loss carryover917 4,715 
Stock-based compensation expense8,670 6,425 
Deferred revenue23,908 25,748 
Research and development capitalization111,704 82,074 
Lease liabilities21,347 21,702 
Hedging contracts27,666 — 
Other454 (3,395)
282,081 221,518 
Less valuation allowance(8,536)(13,572)
Deferred tax assets273,545 207,946 
Deferred tax liabilities:
Goodwill and other intangibles(198,418)(108,078)
Right of use assets(20,501)(20,345)
Property, plant and equipment(12,302)(9,491)
Deferred tax liabilities(231,221)(137,914)
Net deferred tax asset$42,324 $70,032 
As of June 30, 2023, we had $15.6 million of U.S. federal and state net operating loss carryforwards and $6.1 million of non-U.S. net operating loss carryforwards, which expire in various years beginning in 2024 or carry forward indefinitely.
The valuation allowance at June 30, 2023 relates to a provision for uncertainty of the utilization of net operating loss carryforwards of $0.8 million and capital loss and other items of $7.8 million. We believe that it is more likely than not that the benefits of deferred tax assets, net of any valuation allowance, will be realized.
A substantial portion of our manufacturing operations and administrative functions in Singapore operate under certain tax holidays and tax incentive programs that will expire in whole or in part at various dates through June 30, 2030. The end of certain tax holidays may be extended if specific conditions are met. The net impact of these tax holidays and tax incentive programs increased our net income by $40.5 million ($0.27 per diluted share) for the year ended June 30, 2023, $38.0 million ($0.26 per diluted share) for the year ended June 30, 2022, and $33.6 million ($0.23 per diluted share) for the year ended June 30, 2021.
As a result of the Tax Cuts and Jobs Act of 2017 (the “U.S. Tax Act”), we have treated all non-U.S. historical earnings as taxable. Therefore, future repatriation of cash held by our non-U.S. subsidiaries will generally not be subject to U.S. federal tax if repatriated. The total amount of these undistributed earnings at June 30, 2023 amounted to approximately $4.2 billion. In the event our non-U.S. earnings had not been permanently reinvested, approximately $5.5 million in U.S. state deferred taxes would have been recognized in the consolidated financial statements.
The U.S. Tax Act also introduced U.S. taxation on certain global intangible low-taxed income (“GILTI”). We have elected to account for tax expense attributable to GILTI tax as a period cost when incurred.
In accounting for uncertainty in income taxes, we recognize a tax benefit in the financial statements for an uncertain tax position only if management’s assessment is that the position is “more likely than not” (that is, a likelihood greater than 50 percent) to be allowed by the tax jurisdiction based solely on the technical merits of the position. The term “tax position” refers to a position in a previously filed tax return or a position expected to be taken in a future tax return that is reflected in measuring current or deferred income tax assets and liabilities for annual periods. We recognize interest and penalties related to unrecognized tax benefits within the income tax expense line in the accompanying consolidated statements of income. Accrued interest and penalties are included within the related tax liability line in the consolidated balance sheets. Based on all known facts and circumstances and current tax law, we believe the total amount of unrecognized tax benefits on June 30, 2023 is not material to our results of operations, financial condition or cash flows, and if recognized, would not have a material impact on our effective tax rate.
Our income tax returns are based on calculations and assumptions subject to audit by various tax authorities. In addition, the calculation of our tax liabilities involves dealing with uncertainties in the application of complex tax laws. We regularly assess the potential outcomes of examinations by tax authorities in determining the adequacy of our provision for income taxes. Any final assessment resulting from tax audits may result in material changes to our past or future taxable income, tax payable or deferred tax assets, and may require us to pay penalties and interest that could materially adversely affect our financial results.
On September 19, 2021, we concluded the settlement agreement with the Australian Taxation Office (“ATO”) in relation to the previously disclosed transfer pricing dispute for the tax years 2009 through 2018 (“ATO settlement”). The ATO settlement fully resolved the dispute for all prior years, with no admission of liability and provides clarity in relation to certain future taxation principles.
The final net impact of the ATO settlement was recorded during the years ended June 30, 2021 and 2022 in the amount of $238.7 million, which represents a gross amount of $381.7 million, including interest and penalties of $48.1 million, and adjustments for credits and deductions of $143.0 million. As a result of the ATO settlement and due to movements in foreign currencies, we recorded a benefit of $14.1 million within other comprehensive income, and a $4.1 million reduction of tax credits, which was recorded to income tax expense. As a result of the ATO settlement, we reversed our previously recorded uncertain tax position.
On September 28, 2021, we remitted final payment to the ATO of $284.8 million, consisting of the agreed settlement amount of $381.7 million less prior remittances made to the ATO of $96.9 million.
Tax years 2018 to 2022 remain subject to future examination by the major tax jurisdictions in which we are subject to tax.