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Income Taxes
 12 Months Ended
Sep. 30, 2023
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The domestic and foreign pretax income from continuing operations is as follows:
Fiscal Year Ended September 30,
202320222021
(in millions)
Domestic$218 $385 $182 
Foreign391 355 274 
Income before income taxes$609 $740 $456 
Current and deferred income tax expense provided are as follows:
Fiscal Year Ended September 30,
202320222021
(in millions)
Federal:
Current$36 $23 $6 
Deferred(5)44 31 
Foreign:
Current (a)128 128 107 
Deferred(3)(30)(5)
U.S. State:
Current19 21 9 
Deferred(5)(1)1 
Income tax expense$170 $185 $149 
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(a)Includes withholding taxes of $38 million, $27 million and $26 million for the fiscal years ended September 30, 2023, 2022 and 2021, respectively.
The differences between the U.S. federal statutory income tax rate of 21.0% for each of the fiscal years ended September 30, 2023, 2022 and 2021 and income taxes provided are as follows:
Fiscal Year Ended September 30,
202320222021
(in millions)
Taxes on income at the U.S. federal statutory rate$128 $155 $96 
U.S. state and local taxes12 15 10 
Foreign income taxed at different rates, including withholding taxes
34 28 34 
Valuation allowance
(5)(6)(4)
Change in tax rates— 1 10 
GILTI and FDII
(4)(6)(4)
Federal research and development credits(8)— — 
Uncertain tax positions7 (3)— 
Non-deductible compensation
7 6 5 
Other(1)(5)2 
Total income tax expense
$170 $185 $149 
During the fiscal year ended September 30, 2023, the Company recognized a tax benefit of $8 million related to Federal research and development credits, which was partially offset by $7 million of income tax expense arising from an increase in uncertain
tax positions in various jurisdictions. During the fiscal year ended September 30, 2022, the Company recognized a tax benefit of $8 million for the release of valuation allowances in various foreign jurisdictions. During the fiscal year ended September 30, 2021, the Company recognized $10 million of income tax expense arising from an increase in our net UK deferred tax liability due to the change in the UK future statutory tax rate, which was offset by $4 million of excess tax benefits from long term incentive plan, and $6 million for the release of valuation allowances in Mexico and various foreign jurisdictions.
For the fiscal years ended September 30, 2023 and September 30, 2022, the Company incurred losses in certain foreign territories and has offset the tax benefit associated with these losses with a valuation allowance as the Company has determined that it is more likely than not that these losses will not be utilized. Significant components of the Company’s net deferred tax liabilities are summarized below:
September 30,
2023		September 30,
2022
(in millions)
Deferred tax assets:
Allowance and reserves$25 $27 
Employee benefits and compensation71 75 
Other accruals30 27 
Property, plant and equipment40 30 
Operating lease liabilities73 66 
Tax attribute carryforwards59 65 
Deferred revenue and debt17 17 
Total deferred tax assets315 307 
Less: Valuation allowance(25)(29)
Deferred tax assets, net of valuation allowance290 278 
Deferred tax liabilities:
Royalty advances(27)(24)
Operating lease right-of-use assets(60)(52)
Accrued royalties(45)(37)
Intangible assets(318)(333)
Debt and other(24)(23)
Total deferred tax liabilities(474)(469)
Net deferred tax liabilities$(184)$(191)
During the fiscal year ended September 30, 2023, the Company utilized the remaining foreign tax credit carryforwards in the U.S.
At September 30, 2023, the Company has no remaining U.S. federal tax net operating loss carryforwards and $23 million tax net operating loss carryforwards in U.S. state and local jurisdictions that expire in various periods. The Company also has tax net operating loss carryforwards, with no expiration date, in France and Spain of $30 million and $18 million, respectively, and other tax net operating loss carryforwards in foreign jurisdictions that expire in various periods.
Deferred income taxes have not been recorded on indefinitely reinvested earnings of certain foreign subsidiaries of approximately $386 million at September 30, 2023. Distribution of these earnings may result in foreign withholding taxes and U.S. state taxes. However, variables existing if and when remittance occurs make it impracticable to estimate the amount of the ultimate tax liability, if any, on these accumulated foreign earnings.
The Company classifies interest and penalties related to uncertain tax position as a component of income tax expense. As of September 30, 2023 and September 30, 2022, the Company had accrued $2 million and $4 million of interest and penalties, respectively.
The following table reflects changes in the gross unrecognized tax benefits:
Fiscal Year Ended September 30,
202320222021
(in millions)
Gross unrecognized tax benefits - beginning of period$8 $12 $12 
Additions for current year tax positions3 — — 
Additions for prior year tax positions9 1 3 
Subtractions for prior year tax positions(7)(5)(3)
Gross unrecognized tax benefits - end of period$13 $8 $12 
Included in the total unrecognized tax benefits at September 30, 2023 and September 30, 2022 are $14 million and $7 million, respectively, that if recognized, would reduce the effective income tax rate. The Company has determined that it is reasonably possible that the gross unrecognized tax benefits as of September 30, 2023 could decrease by up to approximately $4 million related to various ongoing audits and settlement discussions in various foreign jurisdictions during the next twelve months.
The Company and its subsidiaries file income tax returns in the U.S. and various foreign jurisdictions. The Company has completed tax audits in the U.S. for tax years ended through September 30, 2013, in the UK for the tax years ended through September 30, 2016, in Germany for the tax years ended through September 30, 2014 and in France for the tax years ended through September 30, 2018. The Company is at various stages in the tax audit process in certain foreign and local jurisdictions.
The Organization Economic Co-operation and Development (“OECD”) introduced Base Erosion and Profit Shifting (“BEPS”) Pillar 2 rules that impose a global minimum tax rate of 15%. Numerous countries, including European Union member states, have enacted or are expected to enact legislation to be effective as early as January 1, 2024, with general implementation of a global minimum tax by January 1, 2025. We are currently evaluating the potential impact on our consolidated financial statements and related disclosures.