14. Income Taxes

Income before income taxes is as follows (in millions):

	Year Ended
	April 24, 2015		April 25, 2014		April 26, 2013
Domestic	$	252.9	$	120.5	$	(63.8	)
Foreign		459.9		620.2		630.4
Total	$	712.8	$	740.7	$	566.6

Domestic income before taxes is lower than foreign income before taxes due to significant domestic expenses related to the amortization of intangibles, stock based compensation and, for fiscal years 2014 and 2013, convertible notes interest.

The provision for income taxes consists of the following (in millions):

	Year Ended
	April 24, 2015			April 25, 2014			April 26, 2013
Current:
Federal	$	103.6		$	123.7		$	85.3
State		11.7			14.6			14.6
Foreign		40.3			40.9			38.0
Total current		155.6			179.2			137.9
Deferred:
Federal		8.0			(64.8	)		(56.9	)
State		(3.3	)		(6.1	)		(17.8	)
Foreign		(7.4	)		(5.1	)		(1.9	)
Total deferred		(2.7	)		(76.0	)		(76.6	)
Provision for income taxes	$	152.9		$	103.2		$	61.3

The provision for income taxes differs from the amount computed by applying the statutory federal income tax rate as follows (in millions):

	Year Ended
	April 24, 2015			April 25, 2014			April 26, 2013
Tax computed at federal statutory rate	$	249.5		$	259.2		$	198.3
State income taxes, net of federal benefit		5.4			5.6			(2.0	)
Foreign earnings in lower tax jurisdictions		(141.0	)		(163.3	)		(144.4	)
Stock-based compensation		5.5			9.8			18.4
Research and experimentation credits		(13.7	)		(8.7	)		(12.1	)
Resolution of income tax examinations		46.4			—			0.1
Other		0.8			0.6			3.0
Provision for income taxes	$	152.9		$	103.2		$	61.3

The components of our deferred tax assets and liabilities are as follows (in millions):

	April 24, 2015			April 25, 2014
Deferred tax assets:
Reserves and accruals	$	94.3		$	89.3
Acquired intangibles		43.8			22.3
Net operating loss and credit carryforwards		79.6			87.6
Stock-based compensation		70.4			73.3
Deferred revenue		297.7			318.9
Other		27.0			19.8
Gross deferred tax assets		612.8			611.2
Valuation allowance		(57.7	)		(49.6	)
Deferred tax assets, net of valuation allowance		555.1			561.6
Deferred tax liabilities:
Reserves and accruals		4.0			3.9
Acquired intangibles		13.7			10.0
Property and equipment		26.3			30.8
Other		3.5			2.6
Total deferred tax liabilities		47.5			47.3
Deferred tax assets, net of valuation allowance and deferred tax liabilities	$	507.6		$	514.3

Net deferred tax assets consist of the following (in millions):

April 24,

2015

April 25,

2014

Current deferred tax assets, net

251.7

269.3

Non-current deferred tax assets, net

255.9

245.0

The valuation allowance increased by $8.1 million and $9.8 million in fiscal 2015 and 2014, respectively. The increases are mainly attributable to corresponding changes in deferred tax assets, primarily foreign tax credit carryforwards in a foreign jurisdiction and state tax credit carryforwards in certain states.

As of April 24, 2015, the federal and state net operating loss carryforwards were approximately $21.7 million and $85.4 million, respectively, before applying tax rates for the respective jurisdictions. The federal and state tax credit carryforwards were approximately $117.0 million and $145.5 million, respectively. Certain acquired net operating loss and credit carryforwards are subject to an annual limitation under Internal Revenue Code Section 382, but are expected to be realized with the exception of those which have a valuation allowance. The federal and state net operating loss carryforwards and credits will expire in various years from fiscal 2018 through 2035. If realized, $122.0 million, tax effected, of net operating loss and tax credit carryovers will be recognized as additional paid-in capital.

A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows (in millions):

	Year Ended
	April 24, 2015			April 25, 2014			April 26, 2013
Balance at beginning of period	$	235.9		$	189.6		$	161.0
Additions based on tax positions related to the current year		21.7			26.9			34.5
Additions for tax positions of prior years		101.2			23.8			1.0
Decreases for tax positions of prior years		(29.3	)		(4.4	)		(6.9	)
Settlements		(57.6	)		—			—
Balance at end of period	$	271.9		$	235.9		$	189.6

As of April 24, 2015, we had $271.9 million of gross unrecognized tax benefits, of which $213.6 million has been recorded in other long-term liabilities. Unrecognized tax benefits of $167.5 million, including penalties, interest and indirect benefits, would affect our provision for income taxes if recognized.

We recognize accrued interest and penalties related to unrecognized tax benefits in the income tax provision. During fiscal 2015, 2014 and 2013, we recognized accrued interest and penalties of approximately $3.6 million, $2.2 million and $1.2 million, respectively in the consolidated statements of operations and $8.6 million and $5.0 million, respectively, were recorded in the consolidated balance sheets as of April 24, 2015 and April 25, 2014.

The tax years that remain subject to examination for our major tax jurisdictions are shown below:

Fiscal Years Subject to Examination for Major Tax Jurisdictions at April 24, 2015

2008 — 2015		United States — federal income tax
2008 — 2015		United States — state and local income tax
2011 — 2015		Australia
2009 — 2015		Germany
2006 — 2015		India
2009 — 2015		Japan
2011 — 2015		The Netherlands
2013 — 2015		United Kingdom
2008 — 2015		Canada

In addition, we are effectively subject to federal tax examination adjustments for tax years ended on or after fiscal 2001, in that we have net operating loss carryforwards from these years that could be subject to adjustment upon utilization.

In July 2014, the Internal Revenue Service (IRS) completed the examination of our fiscal 2005 to 2007 income tax returns upon approval by the Joint Committee of Taxation. We recorded a $47.4 million income tax provision attributable to the audit settlement and related re-measurement of uncertain tax positions for tax years subject to future audits. The audit adjustments resulted in lower earnings in our foreign subsidiaries which reduced the taxability of dividends that were previously repatriated from such subsidiaries. Due to this reduction in taxable dividends, the conclusion of the fiscal 2005 to 2007 income tax audit resulted in a net refund of $8.0 million, excluding interest.

In October 2014, the United Kingdom’s (UK’s) tax authority concluded the examination of our fiscal 2009 to 2012 UK income tax returns. We recorded a $1.0 million income tax benefit for the net impact of the audit adjustments and related release of unrecognized tax benefits.

We are currently undergoing federal income tax audits in the United States (U.S.) and several foreign tax jurisdictions. Transfer pricing calculations are key issues under audits in various jurisdictions, and are often subject to dispute and appeals. The IRS is currently auditing our fiscal 2008 to 2010 income tax returns. We expect the IRS examination team to complete their field audit within the next twelve months. However, the resolution of the fiscal 2008 to 2010 income tax return audits may likely occur beyond the next twelve months should we choose to appeal the IRS examination team’s audit findings.

On September 17, 2010, the Danish Tax Authorities issued a decision concluding that distributions declared in 2005 and 2006 from our Danish subsidiary were subject to Danish at-source dividend withholding tax. We do not believe that our Danish subsidiary is liable for withholding tax and filed an appeal with the Danish Tax Tribunal to that effect. On December 19, 2011, the Danish Tax Tribunal issued a ruling that our Danish subsidiary was not liable for Danish withholding tax. The Danish tax examination agency appealed to the Danish High Court in March 2012. The Danish High Court hearing has not yet occurred.

We engage in continuous discussion and negotiation with taxing authorities regarding tax matters in multiple jurisdictions. We believe that within the next 12 months, it is reasonably possible that either certain audits will conclude, certain statutes of limitations will lapse, or both. Given the uncertainties involved in all tax audits, we estimate a potential decrease in our unrecognized tax benefit balance of up to $95.4 million may occur within the next 12 months associated with the potential settlements and statute lapses.

As of April 24, 2015, the amount of accumulated unremitted earnings from our foreign subsidiaries is approximately $3.3 billion. We have not provided U.S. income taxes and foreign withholding taxes on the undistributed earnings of foreign subsidiaries because we intend to permanently reinvest such earnings outside the U.S. If these foreign earnings were to be repatriated in the future, the related U.S. tax liability may be reduced by any foreign income taxes previously paid on these earnings as well as tax attribute carryforwards. We estimate the unrecognized deferred tax liability related to these earnings to be approximately $1 billion as of April 24, 2015.