XML 28 R18.htm IDEA: XBRL DOCUMENT v3.23.4
Income Taxes
 9 Months Ended
Dec. 31, 2023
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The Company’s effective income tax rates were 29.8% and 25.6% for the three months ended December 31, 2023 and 2022, respectively, and 24.7% and 23.3% for the nine months ended December 31, 2023 and 2022, respectively. Our effective tax rates for these periods differ from the federal statutory rate of 21.0% primarily due to the inclusion of state and foreign income taxes and permanent rate differences, which are predominantly related to certain executive compensation and the accrual of reserves for uncertain tax positions, offset by research and development tax credits, excess tax benefits for employee share-based compensation, and the Foreign Derived Intangible Income deduction.
The Company is currently contesting tax assessments from the District of Columbia Office of Tax and Revenue (“DC OTR”) for fiscal years 2013 through 2015. The assessment relates to $11.8 million of taxes, net of federal tax benefits, as of December 31, 2023.
During fiscal 2022, the Company received notification that the District of Columbia Office of Administrative Hearings ruled in favor of the DC OTR. The Company is currently appealing the decision with the District of Columbia Court of Appeals. The Company intends to continue to vigorously defend this matter. Oral arguments occurred on September 26, 2023 and the Company continues to wait on further developments from the court.
The Company has taken similar tax positions with respect to subsequent fiscal years. As of December 31, 2023, the Company does not maintain reserves for any uncertain tax positions related to the contested tax benefits related to 2013 through 2015, nor does it maintain reserves for the similar tax positions taken in the subsequent fiscal years. Management continues to evaluate this position quarterly to determine if a change in estimate is needed. If an adverse final resolution were to occur with respect to the contested tax benefits or the similar tax positions taken for fiscal years 2013 through 2020, the total potential future tax expense that would arise would be approximately $40.4 million to $64.9 million, net of federal benefit.
During fiscal 2023 and through the first and second quarters of fiscal 2024, the Company recognized an increase in reserves for uncertain tax positions related to an increase in research and development tax credits available, as in prior years, and the required capitalization of research and development expenditures, which became effective in fiscal 2023. The uncertain tax positions related to the capitalization of research and development expenditures were offset by a deferred tax asset. As of December 31, 2023, September 30, 2023, and March 31, 2023 the Company recorded $106.8 million, $769.8 million and $552.6 million, respectively, of reserves for uncertain tax positions.
During the third quarter of fiscal 2024, the Company completed a detailed study of its research and development expenditures and confirmed management's position that only certain contracts and activities are required to be capitalized and amortized under the rules enacted as part of the Tax Cuts and Jobs Act of 2017, specifically Section 174. This was further supported by guidance issued by the Internal Revenue Service in September and December 2023. As a result, during the third quarter of fiscal 2024, the Company reversed (i) its uncertain tax position reserve related to Section 174 of $656.2 million, with a corresponding decrease to deferred tax assets, and (ii) the accrued interest on the uncertain tax position related to Section 174 of $5.3 million, which resulted in a decrease in both income tax expense and the uncertain tax position reserve. The Company also adjusted its uncertain tax position reserve related to fiscal 2024 and prior research and development tax credits.
In addition, during the three months ended December 31, 2023, the Company reversed a deferred tax asset of approximately $31.7 million related to the indirect tax benefits of the prior uncertainty around the application of Section 174 of the Tax Cuts and Jobs Act of 2017 (of which approximately $22.0 million was previously recorded in fiscal 2023 and $9.7 million was previously recorded during the six months ended September 30, 2023), which resulted in an increase to income tax expense.
Tax Receivables and Payables
The Company has both income tax receivables and income tax payable on its condensed consolidated balance sheets as follows:
December 31,
2023		March 31,
2023
Current income tax receivable16,635 23,633 
Long term income tax receivable167,821 167,821 
Current income tax payable6,524 14,523 
Current income tax payable represents current liabilities associated with the Company’s current tax returns that the Company intends to file in fiscal 2024 and fiscal 2025. This amount is classified as other current liabilities on the condensed consolidated balance sheets.
The long-term income tax receivable primarily represents the amended U.S. federal return refund claims for research and development tax credits and the carryback claim for the fiscal 2021 net operating loss which is classified as other long-term assets on the condensed consolidated balance sheet. The Company is currently under federal audit by the IRS for fiscal years 2016, 2017 and 2019-2021 and the receipt of our U.S federal return refund claims is contingent upon the completion of the ongoing IRS audits.