INCOME TAXES

The Company’s overall effective tax rate for the three months ended June 27, 2015 and June 28, 2014 was 18.4% and 27.9%, respectively. The Company’s overall effective tax rate was 12.4% and 26.1% for each of the six months ended June 27, 2015 and June 28, 2014, respectively. For the three months ended June 27, 2015 the decrease was primarily attributable to a $1.8 million release of an uncertain tax position resulting from an ability to offset tax on a capital gain from an investment in a limited partnership, the non-taxable bargain purchase gain of $9.9 million associated with the acquisition of Sunrise, and a prior year discrete tax cost of $1.4 million related to nondeductible transaction costs. For the six months ended June 27, 2015, the decrease reflects the items above as well as a reduction in unrecognized tax benefits and related interest of $10.4 million due to the expiration of the statute of limitations associated with pre-acquisition tax positions on forgiveness of debt.

During the three months ended June 27, 2015, the Company’s unrecognized tax benefits decreased by $0.1 million to $23.0 million primarily due to the $1.8 million release resulting from an ability to offset tax on a capital gain from an investment in a limited partnership, offset by the current year reserve associated with Canadian research credits and unfavorable foreign exchange movement. The amount of unrecognized income tax benefits that would impact the effective tax rate decreased by $0.4 million, to $20.1 million. The amount of accrued interest on unrecognized tax benefits was $1.0 million at June 27, 2015. The Company believes that it is reasonably possible that the unrecognized tax benefits will decrease by up to $0.2 million over the next twelve-month period, as a result of the settlement of audits.

The Company conducts business in a number of tax jurisdictions. As a result, it is subject to tax audits in jurisdictions including the U.S., U.K., Japan, France, Germany, and Canada. With few exceptions, the Company is no longer subject to U.S. and international income tax examinations for years before 2011.

The Company and certain of its subsidiaries are currently under audit by various tax authorities in the U.S., Canada, and France. The Company does not believe that resolution of these controversies will have a material impact on its financial position or results of operations.

On December 2, 2014, the Quebec government released Information Bulletin 2014-11, which elaborated on a proposed law change to its SR&ED credit that, if passed, would provide a one-time retroactive benefit to operating income in the year of enactment and would provide a corresponding increase to the Company’s effective income tax rate. If passed as proposed, the tax law change would also provide an ongoing reduction in benefit to operating income and an additional corresponding increase to the Company’s effective income tax rate in the year of enactment and beyond.

In accordance with the Company’s policy, the remaining undistributed earnings of its non-U.S. subsidiaries remain indefinitely reinvested as of the end of the three months ended June 27, 2015 as they are required to fund needs outside the U.S. and cannot be repatriated in a manner that is substantially tax free.

The income tax expense (benefit) related to items of other comprehensive income are as follows:



	Three Months Ended				Six Months Ended
	June 27, 2015		June 28, 2014		June 27, 2015		June 28, 2014
	(in thousands)
Income tax benefit related to foreign currency translation adjustment	$	—	$	—	$	—	$	(105	)
Income tax expense related to change in unrecognized pension gains, losses and prior service costs	263		129		480		253
Income tax expense related to items of other comprehensive income	$	263	$	129	$	480	$	148