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INCOME TAXES
9 Months Ended
Jul. 31, 2018
Income Tax Disclosure [Abstract]  
INCOME TAXES
INCOME TAXES
On December 22, 2017, the President of the United States signed into law the Tax Cuts and Jobs Act of 2017 (the “Tax Reform Act”). The legislation significantly changed U.S. tax law by, among other items, (1) lowering the corporate income tax rate from 35% to 21%, effective January 1, 2018; (2) allowing for the acceleration of expensing of qualified business assets; (3) requiring companies to pay a one-time transition tax on certain unremitted earnings of foreign subsidiaries that may be payable over eight years; (4) adding a new limitation on deductible interest expense; (5) adding limitations on the deductibility of certain executive compensation; and (6) eliminating U.S. federal income tax on dividends from foreign subsidiaries. The corporate income tax rate change was administratively effective as of the beginning of the Company's fiscal 2018 year. Therefore, the Company will use a blended statutory rate for fiscal 2018 of 23.33% on U.S. earnings.
The SEC staff issued Staff Accounting Bulletin No. 118 (“SAB 118”) to address the application of U.S. GAAP in situations when a registrant does not have the necessary information available, prepared, or analyzed (including computations) in reasonable detail to complete the accounting for certain income tax effects of the Tax Reform Act. The Bulletin also provides for a measurement period that should not extend beyond one year from the Tax Reform Act enactment date. As of July 31, 2018, the Company's accounting for the Tax Reform Act is provisional and work is progressing. The Company continues to analyze the earnings and profits and tax pools of its foreign subsidiaries as it relates to transition tax and is completing the final analysis in the revaluation of deferred tax assets and liabilities. However, in accordance with the Bulletin, the Company has recorded a provisional estimate for the following items: a provisional tax benefit related to the revaluation of deferred tax assets and liabilities of $69.3 million and a provisional tax expense as a result of the accrual for the transition tax liability of $35.9 million. Thus, the net provisional tax benefit recorded in the Company’s consolidated financial statements for the nine months ended July 31, 2018 is $33.4 million. Adjustments to the provisional estimates will be recorded and disclosed prospectively during the measurement period and may differ materially from these provisional amounts, due to, among other things, additional analyses, changes in interpretations and assumptions the Company has made, additional regulatory guidance that may be issued, and actions the Company may take as a result of the Tax Reform Act.
Income tax expense for the quarter and year to date was computed in accordance with ASC 740-270 "Income Taxes - Interim Reporting". Under this method, losses from jurisdictions for which a valuation allowance have been provided have not been included in the amount to which the ASC 740-270 rate was applied. Income tax expense of the Company fluctuates primarily due to changes in losses and income from jurisdictions for which a valuation allowance has been provided, the timing of recognition of the related tax expense under ASC 740-270, and the impact of discrete items in the respective quarter.
For the nine months ended July 31, 2018 and July 31, 2017, income tax expense was $31.2 million and $62.0 million, respectively. The large decrease in tax expense for the nine month period relates substantially to the net provisional tax benefit resulting from the re-measurement of deferred tax balances, reduced by the increase in the provisional tax expense related to the transition tax.