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Income Taxes
 12 Months Ended
Dec. 31, 2022
Income Tax Disclosure [Abstract]  
Income Taxes 23. Income Taxes
The components of income before provision for income taxes are as follows:
(in millions)
Year Ended
December 31,
2022		Year Ended
January 1,
2022		Year Ended
January 2,
2021
United States$77.6 $221.2 $214.8 
Foreign115.8 53.2 48.9 
Total
$193.4 $274.4 $263.7 
The following table presents the current and deferred provision (benefit) for income taxes:
(in millions)Year Ended
December 31,
2022		Year Ended
January 1,
2022		Year Ended
January 2,
2021
Current:
Federal$48.7 $38.1 $13.9 
State6.1 7.1 6.4 
Foreign34.4 14.7 8.1 
Subtotal$89.2 $59.9 $28.4 
Deferred:
Federal$(20.5)$(4.9)$1.3 
State(8.7)(6.1)(6.2)
Foreign(10.1)(4.1)(0.1)
Subtotal(39.3)(15.1)(5.0)
Total
$49.9 $44.8 $23.4 
Included in the fiscal year 2022, 2021 and 2020 tax provisions are increases of $4.5 million, $3.6 million and $0.2 million, respectively, for tax and accrued interest related to uncertain tax positions for each fiscal year.
The reconciliation of the U.S. federal statutory tax rate to the Company’s effective tax rate is as follows:
Year Ended
December 31,
2022		Year Ended
January 1,
2022		Year Ended
January 2,
2021
Statutory regular federal income tax rate21.0 %21.0 %21.0 %
State provision, net of federal benefit(1.0)0.3 0.1 
Nondeductible executive compensation2.9 2.1 1.8 
Research and development tax credits(1.7)(1.8)(2.2)
Foreign income taxed at different rates— (0.3)(1.0)
U.S. tax on foreign income, net4.8 0.9 1.0 
Excess stock-based compensation(1.2)(5.5)(10.4)
Derecognition of uncertain tax position(0.8)(1.0)(2.2)
Transaction-related costs0.9 — — 
Other0.9 0.6 0.8 
Total
25.8 %16.3 %8.9 %
As of December 31, 2022, the Company has accumulated undistributed earnings generated by its foreign subsidiaries of approximately $409.1 million. Because such earnings have previously been subject to U.S. tax, any additional taxes due with respect to such earnings or the excess of the amount for financial reporting over the tax basis of its foreign investments would generally be limited to foreign withholding and state taxes. The Company considers $86.5 million of these accumulated undistributed earnings as no longer permanently reinvested and has accrued foreign withholding and state taxes, net of estimated foreign tax credits, of $1.6 million. The Company intends, however, to indefinitely reinvest the remaining $322.6 million of earnings. If the Company decides to distribute such permanently reinvested earnings, the Company would accrue estimated additional income tax expense of up to approximately $15.6 million.
The components of the deferred tax assets are as follows:
(in millions)December 31,
2022		January 1,
2022
Deferred tax assets:
Deferred revenue$27.8 $26.1 
Net operating losses34.7 9.5 
Accrued liabilities32.1 19.2 
Interest22.4 — 
Capitalized R&D18.5 — 
Tax credits18.0 13.1 
Stock-based compensation10.9 8.9 
Operating lease assets8.7 5.7 
Other5.8 — 
Total178.9 82.5 
Valuation allowance(7.3)(6.5)
Total deferred tax assets$171.6 $76.0 
Deferred tax liabilities:
Property and equipment$(18.2)$(13.0)
Intangible assets(186.7)(2.7)
Operating lease liabilities(8.6)(5.4)
Withholding taxes on undistributed foreign earnings(2.8)(2.8)
State taxes and other(7.5)(4.3)
Interest rate hedge(4.1)— 
Inventory(4.0)— 
Other(0.9)(0.4)
Total deferred tax liabilities(232.8)(28.6)
Net deferred tax assets$(61.2)$47.4 
As of December 31, 2022, the Company has $1.2 million and $213.0 million of net operating losses from federal and various state jurisdictions, which will begin to expire in 2037 and 2023, respectively. Additionally, the Company has $76.3 million of net operating losses from foreign jurisdictions that will begin to expire in 2024. The Company also has federal research and development tax credits of $2.8 million that will begin to expire in 2031, state research and development tax credits of $22.4 million that will carry forward indefinitely and $0.9 million of Canadian investment tax credits on research and development expenditures that will begin to expire in 2040. In assessing the realizability of deferred tax assets, the Company considers whether it is more-likely-than-not that all or some portion of the deferred tax assets will not be realized. In making this determination, the Company considered all available positive and negative evidence, including scheduled reversals of liabilities, projected future taxable income, tax planning strategies and recent financial performance.
During the year ended January 1, 2022, the Company established a valuation allowance to reduce the deferred tax assets relating to certain acquired operating losses in certain foreign jurisdictions that the Company believes are not likely to be realized. During the year ended December 31, 2022, there was an increase in the valuation allowance of $0.8 million, primarily due to the losses of certain foreign operations.
As a result of certain business and employment actions undertaken by the Company, income earned in a certain European country is subject to a reduced tax rate through 2022, which, upon meeting certain requirements, can be extended through 2026. For the year ended December 31, 2022 and January 1, 2022, the estimated income tax benefit related to such business arrangement was $1.7 million and $1.0 million, respectively, and favorably impacted net income per diluted share by $0.03 for each year.
The following is a tabular reconciliation of the total amounts of unrecognized tax benefits:
(in millions)Year Ended
December 31,
2022		Year Ended
January 1,
2022
Unrecognized tax benefits (gross), beginning of period$21.6 $18.0 
Increase from tax positions in prior period0.7 0.6 
Decrease from tax position in prior period(0.6)(0.9)
Increase from tax positions in current period6.0 7.0 
Lapse of statute of limitations(1.6)(3.1)
Unrecognized tax benefits (gross), end of period$26.1 $21.6 
The amount of unrecognized benefits which, if ultimately recognized, could favorably affect the tax rate in a future period was $24.0 million and $19.8 million as of December 31, 2022 and January 1, 2022, respectively. It is reasonably possible that the amount of unrecognized tax benefits in various jurisdictions may change in the next 12 months due to the expiration of statutes of limitation and audit settlements. However, due to the uncertainty surrounding the timing of these events, an estimate of the change within the next 12 months cannot be made at this time.
For the year ended December 31, 2022 the Company recorded an expense of $0.3 million for interest and penalties related to unrecognized tax benefits as part of income tax expense. For the year ended January 1, 2022, the Company recorded a benefit of $0.1 million for interest and penalties related to unrecognized tax benefits as part of income tax expense.
Total accrued interest and penalties related to unrecognized tax benefits as of December 31, 2022 and January 1, 2022 were $1.1 million and $0.8 million, respectively.
The Company conducts business in multiple jurisdictions, and as a result, one or more of the Company’s subsidiaries files income tax returns in the U.S. federal, various state, local and foreign jurisdictions. The Company has concluded all U.S. federal income tax matters for years through 2018. All material state, local and foreign income tax matters have been concluded for years through 2015.
In March 2020, the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act) was enacted and signed into law in response to the market volatility and instability resulting from the COVID-19 pandemic. It includes a significant number of tax provisions and lifts certain deduction limitations originally imposed by the 2017 Tax Cuts and Jobs Act of 2017. The changes are primarily related to: (1) the business interest expense disallowance rules for 2019 and 2020; (2) net operating loss rules; (3) charitable contribution limitations; (4) employee retention credit; and (5) the realization of corporate alternative minimum tax credits.
The Company has reviewed the tax provision in the CARES Act and did not identify any material impact to the Company’s consolidated financial statements.