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Income Taxes
6 Months Ended
Apr. 02, 2021
Income Tax Disclosure [Abstract]  
Income Taxes INCOME TAXES:
On March 27, 2020, 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 a net benefit to the (Benefit) Provision for Income Taxes of approximately $12.1 million and $34.3 million during the three and six month periods ended April 2, 2021, respectively, which reflect the NOLs expected to be carried back to Pre-TCJA tax years at 35.0%. In addition, the Company recorded a valuation allowance to the (Benefit) Provision for Income Taxes of $10.1 million and $26.2 million during the three and six month periods ended April 2, 2021, respectively, against certain foreign tax credits ("FTCs") that were re-established by the NOL carryback, as it is more likely than not a tax benefit will not be realized.
As of April 2, 2021, the Company had an income tax receivable balance of approximately $3.1 million, which primarily reflects the expected remaining proceeds to be refunded for NOLs generated in fiscal 2020 and through the six months of fiscal 2021 based on the carry back to Pre-TCJA years. During the second quarter of fiscal 2021, the Company received approximately $93.6 million of proceeds related to the fiscal 2020 income tax return from the NOLs generated in fiscal 2020 as a result of the CARES Act. The Company also recorded an additional $138.4 million of FTCs and $4.9 million of general business credits in "Deferred Income Taxes and Other Noncurrent Liabilities" on the Condensed Consolidated Balance Sheets that will be used to offset future federal income tax liabilities as of April 2, 2021. The $138.4 million of FTCs are partially offset by the $26.2 million valuation allowance recorded as of April 2, 2021. The Company continues 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 in certain subsidiaries in the FSS International segment as negative evidence, the Company recorded a valuation allowance against DTAs of approximately $14.4 million within the Condensed Consolidated Statements of Loss during the three and six month periods ended April 2, 2021.