8. Income Taxes

The provision for income taxes is based on reported income before income taxes. Deferred income tax assets and liabilities reflect the impact of temporary differences between the amounts of assets and liabilities recognized for financial reporting purposes and the amounts recognized for tax purposes, as measured by applying the currently enacted tax laws.

The provision (benefit) for domestic and foreign income taxes was as follows:


	Year Ended April 30,
	2015			2014			2013
	(in thousands)
Current income taxes:
Federal	$	16,569		$	6,982		$	4,100
State		2,412			1,939			1,237
Foreign		13,650			15,502			8,759

Current provision for income taxes		32,631			24,423			14,096
Deferred income taxes:
Federal		3,140			5,094			(423	)
State		(239	)		177			1,895
Foreign		(2,006	)		(1,202	)		1,069

Deferred provision for income taxes		895			4,069			2,541

Total provision for income taxes	$	33,526		$	28,492		$	16,637

The domestic and foreign components of income from continuing operations before domestic and foreign income and other taxes and equity in earnings of unconsolidated subsidiaries were as follows:


	Year Ended April 30,
	2015		2014		2013
	(in thousands)
Domestic	$	65,885	$	42,411	$	15,915
Foreign		53,817		56,603		31,905

Income before provision for income taxes and equity in earnings of unconsolidated subsidiaries	$	119,702	$	99,014	$	47,820

The reconciliation of the statutory federal income tax rate to the effective consolidated tax rate is as follows:


	Year Ended April 30,
	2015			2014			2013
U.S. federal statutory income tax rate		35.0	%		35.0	%		35.0	%
Foreign source income, net of credits generated		0.4			2.0			0.6
Foreign tax rates differential		(4.2	)		(4.7	)		(3.7	)
COLI increase, net		(3.1	)		(2.9	)		(4.8	)
Conclusion of U.S. federal tax audit		—			(2.7	)		—
State income taxes, net of federal benefit		0.9			1.5			5.7
Change in uncertain tax positions		(0.1	)		1.1			1.9
Other		(0.9	)		(0.5	)		0.1

Effective income tax rate		28.0	%		28.8	%		34.8	%

In fiscal 2014, we recorded a tax benefit in connection with the conclusion of an IRS examination of the Company’s U.S. federal income tax returns for tax years ended April 30, 2010 and 2011. Subsequently, we filed amended state income tax returns to report the federal adjustments and, where permissible, combined certain of our subsidiaries that had previously filed separate tax returns into unitary filings that resulted in a state tax benefit in fiscal 2015.

Components of deferred tax assets and liabilities are as follows:


	April 30,
	2015			2014
	(in thousands)
Deferred tax assets:
Deferred compensation	$	71,182		$	66,359
Loss and credit carryforwards		26,211			35,177
Reserves and accruals		9,344			8,706
Deferred rent		6,432			5,575
Deferred revenue		277			1,672
Allowance for doubtful accounts		1,831			1,536
Other		6,629			6,531

Gross deferred tax assets		121,906			125,556

Deferred tax liabilities:
Intangibles		(20,828	)		(21,507	)
Property and equipment		(6,289	)		(6,277	)
Prepaid expenses		(7,687	)		(5,600	)
Other		(5,653	)		(5,678	)

Gross deferred tax liabilities		(40,457	)		(39,062	)

Valuation allowances		(21,608	)		(26,969	)

Net deferred tax asset	$	59,841		$	59,525

The decrease in the valuation allowance primarily reflects an offsetting decrease in foreign deferred tax assets, predominantly net operating losses, due to exchange rates.

The deferred tax amounts have been classified in the consolidated balance sheets as follows:


	April 30,
	2015			2014
	(in thousands)
Current:
Deferred tax assets	$	14,600		$	15,591
Deferred tax liabilities		(10,488	)		(10,813	)
Valuation allowance		(285	)		(292	)

Current deferred tax asset		3,827			4,486

Non-current:
Deferred tax asset		107,306			109,965
Deferred tax liabilities		(29,969	)		(28,249	)
Valuation allowance		(21,323	)		(26,677	)

Non-current deferred tax asset, net		56,014			55,039

Net deferred tax assets	$	59,841		$	59,525

Deferred tax assets are reduced by a valuation allowance if it is more likely than not that some portion or all of the deferred tax asset will not be realized. Management believes uncertainty exists regarding the realizability of certain operating losses and has, therefore, established a valuation allowance for this portion of the deferred tax asset. Realization of the deferred income tax asset is dependent on the Company generating sufficient taxable income of the appropriate nature in future years. Although realization is not assured, management believes that it is more likely than not that the net deferred income tax assets will be realized.

As of April 30, 2015 and 2014, the Company had U.S. federal net operating loss carryforwards of $5.0 million and $12.2 million, respectively, from the acquisition of PDI, which will begin to expire in 2028. The utilization of these losses is subject to an annual limitation as defined under Section 382 of the Internal Revenue Code. The Company has state net operating loss carryforwards of $21.8 million, which, if unutilized, will begin to expire in fiscal year 2016. The Company also has foreign net operating loss carryforwards of $85.6 million, which, if unutilized, will begin to expire in fiscal year 2016.

The Company has a plan to distribute a portion of the cash held in foreign locations to the U.S. These planned distributions will not give rise to any additional taxes. Other than these amounts, the Company has not provided for U.S. taxes or foreign withholding taxes on approximately $241.8 million of undistributed earnings of its foreign subsidiaries as such earnings are intended to be reinvested indefinitely. If a distribution of these earnings were to be made, the Company might be subject to both foreign withholding taxes and U.S. income taxes, net of any allowable foreign tax credits or deductions. An estimate of these taxes, however, is not practicable.

The Company or one of its subsidiaries files federal and state income tax returns in the U.S. as well as in foreign jurisdictions. These income tax returns are subject to audit by the Internal Revenue Service (the “IRS”) and various state and foreign tax authorities. In June 2014, the IRS commenced an examination of the Company’s fiscal year 2013 U.S. federal income tax return. The Company’s income tax returns are not otherwise under examination in any material jurisdiction. The statute of limitations varies by jurisdiction in which the Company operates. With few exceptions, however, the Company’s tax returns for years prior to fiscal year 2010 are no longer open to examination by tax authorities (including U.S. federal, state and foreign).

Unrecognized tax benefits are the differences between the amount of benefits of tax positions taken, or expected to be taken, on a tax return and the amount of benefits recognized for financial reporting purposes. As of April 30, 2015, the Company had a liability of $2.4 million for unrecognized tax benefits. A reconciliation of the beginning and ending balances of the unrecognized tax benefits is as follows:


	Year Ended April 30,
	2015			2014			2013
	(in thousands)
Unrecognized tax benefits, beginning of year	$	2,701		$	3,400		$	—
Settlement with tax authority		(497	)		(1,946	)		—
Additions based on tax positions related to the current year		219			279			1,454
Additions based on tax positions related to prior years		—			968			1,946

Unrecognized tax benefits, end of year	$	2,423		$	2,701		$	3,400

The liability for unrecognized tax benefits is included in income taxes payable in the consolidated balance sheets. The full amount of unrecognized tax benefits would impact the effective tax rate if recognized. In the next twelve months, it is reasonably possible that the Company’s unrecognized tax benefits could change due to resolution of certain tax matters, which could include payments on those tax matters. These resolutions and payments could reduce the Company’s liability for unrecognized tax benefits balance by approximately $1.4 million.

The Company classifies interest and penalties related to unrecognized tax benefits as a component of the provision for income taxes. The Company had approximately $0.7 million in accrued interest and penalties related to unrecognized tax benefits as of April 30, 2015 and 2014. The Company accrued approximately $0.1 million of interest related to unrecognized tax benefits in fiscal 2015 and fiscal 2014 and none in fiscal 2013.