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Income Taxes
12 Months Ended
Dec. 31, 2019
Income Tax Disclosure [Abstract]  
Income Taxes
1
6
)
Income Taxes
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The Tax Cuts and Jobs Act (“the Act”), which was enacted
on December 22, 2017, reduced the U.S. federal corporate tax rate from 35% to 21% effective
January 1, 2018, required companies to pay a
one-time
transition tax on earnings of certain foreign subsidiaries that were previously tax deferred and created new taxes on certain foreign sourced earnings. The Company applied SAB 118 when accounting for the enactment effects of the Act. During the quarter ended December 31, 2018, the Company completed and recorded the impacts of the Act based on its understanding and interpretation of the regulatory guidance issued.
A reconciliation of the Company’s effective tax rate to the U.S. federal statutory rate is as follows:
 
Years Ended December 31,
 
 
    2019    
 
 
    2018    
 
 
    2017    
 
U.S. Federal income tax statutory rate
 
 
21.0
%
 
 
21.0
%
 
 
35.0
%
Federal tax credits
 
 
(2.9
)
 
 
(0.7
)
 
 
(0.7
)
State income taxes, net of federal benefit
 
 
2.3
 
 
 
1.3
 
 
 
1.0
 
Effect of foreign operations taxed at various rates
 
 
(4.4
)
 
 
(1.3
)
 
 
(12.1
)
Qualified production activity tax benefit
 
 
 
 
 
 
 
 
(1.4
)
Executive compensation
 
 
5.8
 
 
 
 
 
 
 
Gain on intercompany sale of assets
 
 
2.9
 
 
 
 
 
 
 
Benefit of a capital loss
 
 
(1.2
)
 
 
 
 
 
 
Foreign derived intangible income deduction
 
 
(3.8
)
 
 
(2.1
)
 
 
 
Global intangible low taxed income, net of foreign tax credits
 
 
2.6
 
 
 
0.4
 
 
 
 
Transition tax, net of foreign tax credits
 
 
 
 
 
(0.1
)
 
 
6.4
 
Revaluation of deferred income taxes
 
 
(1.4
)
 
 
(0.3
)
 
 
(5.0
)
Revaluation of prepaid taxes
 
 
 
 
 
1.6
 
 
 
 
Stock-based compensation
 
 
(0.3
)
 
 
(1.3
)
 
 
(2.5
)
Deferred tax asset valuation allowance
 
 
0.1
 
 
 
 
 
 
(0.1
)
Release of income tax reserves (including interest)
 
 
(0.8
)
 
 
(0.4
)
 
 
(0.4
)
Foreign dividends, net of foreign tax credits
 
 
0.6
 
 
 
(1.0
)
 
 
3.3
 
Other
 
 
0.6
 
 
 
1.2
 
 
 
0.7
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
21.1
%
 
 
18.3
%
 
 
24.2
%
 
 
 
 
 
 
 
 
 
 
 
 
 
The effective tax rate for 2019 includes a correction of an out of period error with respect to deferred tax assets related to limitations on the deduction of executive compensation in the amount of $5,023. This correction, which should have been recorded during the three months ended September 30, 2018, increased the Company’s effective tax rate for the year ended December 31, 2019 by approximately 2.8%. 
The components of income from operations before income taxes and the related provision for income taxes consist of the following:
 
Years Ended December 31,
 
 
2019
 
 
2018
 
 
2017
 
Income before income taxes:
   
     
     
 
United States
  $
 2,279
    $
287,309
    $
224,979
 
Foreign
   
175,557
     
193,641
     
222,646
 
                         
  $
 177,836
    $
480,950
    $
447,625
 
                         
Current taxes:
   
     
     
 
United States
  $
 6,790
    $
41,428
    $
77,023
 
State
   
2,068
     
8,094
     
6,149
 
Foreign
   
32,807
     
57,920
     
30,152
 
                         
   
41,665
     
107,442
     
113,324
 
Deferred taxes:
   
     
     
 
United States
   
(1,743
   
(2,533
)    
(16,250
)
State and Foreign
   
(2,472
   
(16,855
)    
11,419
 
                         
   
(4,215
   
(19,388
)    
(4,831
)
                         
Provision for income taxes
  $
37,450
    $
88,054
    $
108,493
 
                         
The significant components of the deferred tax assets and deferred tax liabilities are as follows:
 
Years Ended December 31,
 
 
    2019    
 
 
    2018    
 
Deferred tax assets:
   
     
 
Carry-forward losses and credits
  $
 59,189
    $
23,675
 
Inventory and warranty reserves
   
29,661
     
17,945
 
Accrued expenses and other reserves
   
12,607
     
10,260
 
Stock-based compensation
   
8,580
     
5,351
 
Executive supplemental retirement benefits
   
1,556
     
5,972
 
Lease liability
 
 
15,284
 
 
 
 
Unrealized net loss
 
 
2,741
 
 
 
 
Other
   
2,347
     
2,396
 
                 
Total deferred tax assets
  $
131,965
    $
65,599
 
                 
Deferred tax liabilities:
   
     
 
Acquired intangible assets
 and 
goodwi
ll
  $
(128,144
)   $
(74,120
)
Depreciation and amortization
   
(14,072
)    
(8,332
)
Loan costs
   
(2,317
)    
(1,108
)
Right-of-use
asset
 
 
(14,415
)
 
 
 
Foreign withholding taxes
   
(5,008
)    
(3,176
)
Unrealized net gain
   
     
(1,952
)
                 
Total deferred tax liabilities
   
(163,956
)    
(88,688
)
                 
Valuation allowance
   
(27,360
)    
(17,936
)
                 
Net deferred tax liabilities
  $
(59,351
)   $
(41,025
)
                 
Due to the reduction in U.S. federal statutory tax rate from the enactment of the Act, the Company recorded a provisional adjustment reducing its net deferred tax liabilities by $
22,345
as of December 31, 2017. This provisional adjustment was finalized during the year ended December 31, 2018 and an additional tax provision of $
2,614
was recorded.
As of December 31, 2019, the
C
ompany ha
d
federal, state and foreign gross research and other tax credit carry-forwards of $
64,983
.
Included in the total carry-forward are $
14,230
of credits that can be carried forward indefinitely and the remaining credits expire at various dates through 2037. The
C
ompany also had
 f
e
deral
, state and foreign gross net operating loss and capital loss carry-forwards of $
98,280
. Included in the total carry-forward are $
57,588
of losses that can be carried forward indefinitely while the remaining losses expire at various dates through
2037
.
Although the Company believes that its tax positions are consistent with applicable U.S. federal, state and international laws, it maintains certain tax reserves as of December 31, 2019 in the event its tax positions were to be challenged by the applicable tax authority and additional tax assessed upon audit.
A reconciliation of the beginning and ending amount of gross unrecognized tax benefits is as follows:
 
Years Ended December 31,
 
 
2019
 
 
2018
 
 
2017
 
Balance at beginning of year
  $
 32,684
    $
27,345
    $
25,465
 
Increases
 
for prior years
   
9,324
     
934
     
640
 
Increases for the current year
   
3,219
     
6,091
     
4,340
 
Reductions related to expiration of statutes of limitations and audit settlements
   
(1,734
)    
(1,686
)    
(3,100
)
                         
Balance at end of year
  $
43,493
    $
32,684
    $
27,345
 
                         
As of December 31, 2019, the total gross unrecognized tax benefits, which excludes interest and penalties, was $43,493. As of December 31, 2018, the total gross unrecognized tax benefits, which excludes interest and penalties,
was $32,684.
The net increase was primarily attributable to the addition of historical gross unrecognized tax benefits for ESI as a result of the ESI Merger during the quarter ended March 31, 2019.
The Company accrues interest and, if applicable, penalties for any uncertain tax positions. Interest and penalties are classified as a component of income tax expense. As of December 31, 2019, 2018 and 2017, the Company had accrued interest on unrecognized tax benefits of approximately $527, $568 and $327, respectively.
Over the next 12 months it is reasonably possible that the Company may recognize $1,463 of previously net unrecognized tax benefits, excluding interest and penalties, related to various U.S. federal, state and foreign tax positions primarily due to the expiration of statutes of limitations.
The Company and its subsidiaries are subject to examination by U.S. federal, state and foreign tax authorities. The U.S. Internal Revenue Service commenced an examination of the Company’s U.S. federal income tax filings for tax years 2015 and 2016 during the quarter ended September 30, 2017. This audit was effectively settled during the quarter ended March 31, 2018, and the impact was not material. Also, during the quarter ended March 31, 2018, the Company received notification from the U.S. Internal Revenue Service of their intent to audit its U.S. subsidiary, Newport, for the tax year 2015. This audit commenced during the quarter
ended June 30, 2018 and was effectively settled during the quarter ended June 30, 2019, with a no change result. The U.S. statute of limitations remains open for tax years 2016 through the present. The statute of limitations for the Company’s tax filings in other jurisdictions varies between fiscal years 2014 through present. The Company has certain federal credit carry-forwards and state tax loss and credit carry-forwards that are open to examination for tax years 2000 through the present.
On a quarterly basis, the Company evaluates both positive and negative evidence that affects the realizability of net deferred tax assets and assesses the need for a valuation allowance. The future benefit to be derived from its deferred tax assets is dependent upon its ability to generate sufficient future taxable income to realize the assets.
During 2019, the Company increased its valuation allowance by $9,424. This increase was primarily attributable to the addition of historical valuation allowances for ESI and its subsidiaries which were included as a result of the ESI Merger during the quarter ended March 31, 2019. During 2018, the Company increased its valuation allowance by $4,307, primarily related to certain tax credit and net operating loss carry-forward amounts. During 2017, the Company increased its valuation allowance by $1,102, primarily related to certain state tax credits.
No provision has been made for deferred taxes related to remaining historical outside basis differences in certain of the Company’s
non-US
subsidiaries. The Company continues to assert indefinite reinvestment in these outside basis differences generated on or before December 31, 2019. Determination of the amount of unrecognized deferred tax liability on outside basis differences is not practicable because the amount of such liability, if any, is dependent upon circumstances existing and tax planning choices available when a transaction using outside basis occurs.
Certain of the Company’s subsidiaries have obtained tax rate reductions or tax holidays under incentive programs offered under government programs. A Singapore subsidiary of ESI obtained a tax holiday in Singapore. The benefits of the holiday w
ere
 approximately $2.2 million
($0.04 per share)
in 2019. The tax holiday in Singapore is expected to expire at the end of June 2021.