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INCOME TAXES | 12 Months Ended
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Nov. 30, 2024
Income Tax Disclosure [Abstract] |
INCOME TAXES | INCOME TAXES: The sources of income before the provision for income taxes are as follows:
| Fiscal Years Ended November 30,
| 2024 |  | 2023 |  | 2022
United States | $ | 4,279 |  |  | $ | (51,820) |  |  | $ | 7,883 |
Foreign | 294,995 |  |  | 460,048 |  |  | 597,120 |
Total income before income taxes | $ | 299,274 |  |  | $ | 408,228 |  |  | $ | 605,003 |
Provision for income taxes consists of the following:
| Fiscal Years Ended November 30,
| 2024 |  | 2023 |  | 2022
Current tax provision: |  |  |  |  |
Federal | $ | 89,987 |  |  | $ | 78,961 |  |  | $ | 65,423 |
State | 7,734 |  |  | 11,064 |  |  | 5,151 |
Foreign | 185,584 |  |  | 126,072 |  |  | 129,613 |
| $ | 283,305 |  |  | $ | 216,097 |  |  | $ | 200,187 |
Deferred tax provision (benefit): |  |  |  |  |
Federal | $ | (104,236) |  |  | $ | (97,371) |  |  | $ | (19,596) |
State | (20,462) |  |  | (12,850) |  |  | (12,303) |
Foreign | (110,550) |  |  | (11,490) |  |  | 1,075 |
| (235,248) |  |  | (121,711) |  |  | (30,824) |
Total income tax provision | $ | 48,057 |  |  | $ | 94,386 |  |  | $ | 169,363 |
The following presents the breakdown of net deferred tax liabilities after netting by taxing jurisdiction:
| As of November 30,
| 2024 |  | 2023
Deferred tax assets | $ | 218,396 |  |  | $ | 72,333 |
Deferred tax liabilities | 312,574 |  |  | 414,246 |
Total net deferred tax liabilities | $ | 94,178 |  |  | $ | 341,913 |
Net deferred tax liabilities consist of the following:
| As of November 30,
| 2024 |  | 2023
Assets: |  |  |
Net operating losses | $ | 172,182 |  |  | $ | 138,930 |
Accruals and other reserves | 78,308 |  |  | 55,528 |
Depreciation and amortization | 107,095 |  |  | 73,234 |
U.S. interest limitation carry forward | 49,481 |  |  | 33,318 |
Share-based compensation expense | 17,714 |  |  | 7,867 |
Deferred revenue | 5,280 |  |  | 5,429 |
Tax credits | 5,082 |  |  | 5,082 |
Foreign tax credit | 5,199 |  |  | 915 |
Operating lease liabilities | 201,266 |  |  | 190,348 |
Intercompany loans payable | 110,708 |  |  | 81,654 |
Other | 32,048 |  |  | 37,713 |
Gross deferred tax assets | 784,363 |  |  | 630,018 |
Valuation allowance | (125,163) |  |  | (117,679) |
Total deferred tax assets | $ | 659,200 |  |  | $ | 512,339 |
Liabilities: |  |  |
Intangible assets | $ | 529,129 |  |  | $ | 636,194 |
Unremitted non-US earnings | 42,433 |  |  | 45,250 |
Operating lease right-of-use assets | 181,816 |  |  | 172,808 |
Total deferred tax liabilities | 753,378 |  |  | 854,252 |
Net deferred tax liabilities | $ | 94,178 |  |  | $ | 341,913 |
The valuation allowance relates primarily to certain state and foreign net operating loss carry forwards, foreign deferred items and state credits. The Company’s assessment is that it is not more likely than not that these deferred tax assets will be realized. A reconciliation of the statutory U.S. federal income tax rate to the Company’s effective income tax rate is as follows:
| Fiscal Years Ended November 30,
| 2024 |  | 2023 |  | 2022
Federal statutory income tax rate | 21.0 | % |  | 21.0 | % |  | 21.0 | %
State taxes, net of federal income tax benefit | (1.8) | % |  | (1.0) | % |  | (1.4) | %
International rate difference | (9.0) | % |  | (2.3) | % |  | (2.7) | %
Withholding taxes | 3.9 | % |  | 2.5 | % |  | 1.1 | %
Uncertain tax benefits | 0.7 | % |  | 1.3 | % |  | (0.3) | %
Changes in valuation allowance | 6.5 | % |  | 1.7 | % |  | 1.3 | %
Impact of inclusion of foreign income (1) | 0.3 | % |  | (4.7) | % |  | 9.2 | %
Capital loss | (12.4) | % |  | — | % |  | — | %
Other (2) | 6.9 | % |  | 4.6 | % |  | (0.2) | %
Effective income tax rate | 16.1 | % |  | 23.1 | % |  | 28.0 | %
(1) Represents Subpart F income, Base Erosion and Anti-Abuse Tax (BEAT), and Global Intangible Low-Taxed Income (GILTI) (less Section 250 deduction), net of associated foreign tax credits. (2) Includes categories of reconciling items that are not individually equal to or greater than 5% for the fiscal year ended November 30, 2024. Includes tax costs related to future legal entity restructuring for the fiscal year ended November 30, 2023. The Company’s U.S. business has sufficient cash flow and liquidity to fund its operating requirements and the Company expects and intends that profits earned outside the United States will be fully utilized and reinvested outside of the United States with the exception of earnings of certain acquired non-U.S. entities. The Company has recorded deferred tax liabilities related to non-U.S. withholding taxes on the earnings of its non-U.S. subsidiaries likely to be repatriated in the future. As of November 30, 2024, the Company had approximately $2,757,788 of undistributed earnings of its non-U.S. subsidiaries for which it has not provided for non-U.S. withholding taxes and state taxes because such earnings are intended to be reinvested indefinitely in international operations. It is not practicable to determine the amount of applicable taxes that would be due if such earnings were distributed. Accordingly, the Company has not provisioned U.S. state taxes and non-U.S. withholding taxes on the non-U.S. legal entities for which the earnings are permanently reinvested. As of November 30, 2024, the Company had net operating loss carry forwards of approximately $312,542 and $29,544 for federal and state purposes, respectively. The federal net operating loss carry forward and the state net operating loss carry forwards will begin to expire in the fiscal year ending November 30, 2025. The Company also had approximately $173,322 of foreign net operating loss carry forwards that will also begin to expire in fiscal year ending November 30, 2025 if not used. In addition, the Company has approximately $10,670 of various federal and state income tax credit carry forwards that, if not used, will begin to expire in the fiscal year ending November 30, 2025. Utilization of the acquired loss carry forwards may be limited pursuant to Section 382 of the Internal Revenue Code of 1986. The Company enjoys tax holidays in certain jurisdictions, primarily Algeria, China, Colombia, Costa Rica, Dominican Republic, El Salvador, Estonia, Guatemala, Honduras, India, Jamaica, Jordan, Latvia, Madagascar, Nicaragua, the Philippines and Türkiye. The tax holidays provide for lower or zero rates of taxation and require various thresholds of investment and business activities in those jurisdictions. The estimated tax benefits from the above tax holidays for fiscal years 2024, 2023, and 2022 were approximately $17,332, $7,961, and $10,315, respectively. The aggregate changes in the balances of gross unrecognized tax benefits, excluding accrued interest and penalties, during fiscal years 2024, 2023, and 2022 were as follows:
Balance as of November 30, 2021 | $ | 47,447 |
Additions based on tax positions related to the current year | 42,749 |
Settlements | (4,882) |
Lapse of statute of limitations | (14,351) |
Balance as of November 30, 2022 | 70,963 |
Additions based on tax positions related to the current year | 5,819 |
Additions based on tax positions related to the prior year / acquisition | 6,071 |
Lapse of statute of limitations | (4,938) |
Changes due to translation of foreign currencies | 1,407 |
Balance as of November 30, 2023 | 79,322 |
Additions based on tax positions related to the current year | 11,081 |
Additions based on tax positions related to the prior year / acquisition | 18,576 |
Lapse of statute of limitations | (8,071) |
Changes due to translation of foreign currencies | (132) |
Settlements | (428) |
Balance as of November 30, 2024 | $ | 100,348 |
The Company conducts business globally and files income tax returns in various U.S. and non-U.S. jurisdictions. The Company is subject to continuous examination and audits by various tax authorities. Significant audits are underway in the United States and India. The Company is not aware of any material exposures arising from these tax audits or in other jurisdictions not already provided for. Although timing of the resolution of audits and/or appeals is highly uncertain, the Company believes it is reasonably possible that the total amount of unrecognized tax benefits as of November 30, 2024 could decrease between $40,219 and $42,796 in the next twelve months. The Company is no longer subject to U.S. federal income tax audit for returns covering years through fiscal year 2018. The Company is no longer subject to non-U.S. or U.S. state income tax audits for returns covering years through fiscal year 2012 and fiscal year 2014, respectively. The liability for unrecognized tax benefits was $112,961 and $87,939 at November 30, 2024 and November 30, 2023, respectively, and is included in other long-term liabilities in the consolidated balance sheets. As of November 30, 2024 and 2023, $60,512 and $52,779 of the total unrecognized tax benefits, net of federal benefit, would affect the effective tax rate, if realized. The Company’s policy is to include interest and penalties related to income taxes, including unrecognized tax benefits, within the provision for income taxes. As of November 30, 2024 and 2023, the Company had accrued $12,613 and $8,617, respectively, in income taxes payable related to accrued interest and penalties.

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