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Income Taxes
6 Months Ended
Mar. 27, 2020
Income Tax Disclosure [Abstract]  
Income Tax Disclosure INCOME TAXES:
On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act (the "CARES Act") was enacted in response to COVID-19. The CARES Act, among other things, permits net operating losses ("NOLs") incurred in fiscal 2019, 2020 and 2021 to be carried back to each of the five preceding taxable years to generate a refund of previously paid income taxes. NOLs arising in fiscal 2019, 2020, or 2021 are created in years that have a 21.0% federal income tax rate. If these NOLs are carried back to years prior to fiscal 2018, the resulting refund would be in years with a 35.0% federal income tax rate.
The CARES Act contains modifications on the limitation of business interest for fiscal years 2020 and 2021 to increase the allowable business interest deduction from 30.0% of adjusted taxable income to 50.0% of adjusted taxable income. The CARES Act also includes a technical correction to the Tax Cut and Jobs Act (the "TCJA") that provides that Qualified Improvement Property ("QIP"), which includes almost any improvement to the interior of leased or owned space, is eligible for bonus depreciation retroactively to the January 1, 2018 effective date of the TCJA.
As a result of the CARES Act, the Company recorded an income tax expense of approximately $3.7 million for both the three and six month periods of fiscal 2020. While the Company's estimated annual effective tax rate reflects a benefit from the CARES Act, the application of that rate to the ordinary pretax income resulted in an expense for the three months ended March 27, 2020. The Company will continue to monitor and assess the impact the CARES Act and similar legislation in other countries may have on the Company's business and financial results.
As of each reporting date, the Company considers existing evidence, both positive and negative, that could impact the need for valuation allowances against deferred tax assets ("DTAs"). Based on cumulative losses and goodwill impairment recorded in the FSS International segment (see Note 4) as negative evidence, the Company recorded a valuation allowance against DTAs of certain subsidiaries in the amount of approximately $8.6 million in the quarter ending March 27, 2020.
The effective tax rate for the three and six months ended March 27, 2020 also includes tax benefits of approximately $26.9 million and $45.5 million as a result of an excess tax benefit recognized in relation to equity awards exercised during the first and second quarters of fiscal 2020, including by the former Chairman, President and Chief Executive Officer.
The (Loss) Income Before Income Taxes for the three and six month periods of fiscal 2020 includes a non-cash impairment charge of goodwill for $198.6 million, which is nondeductible for income tax purposes (see Note 4).