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INCOME TAXES
3 Months Ended
Jan. 31, 2019
Income Tax Disclosure [Abstract]  
INCOME TAXES
INCOME TAXES
The Tax Cuts and Jobs Act of 2017 (the “Tax Reform Act”), which went into law on December 22, 2017, has 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 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 U.S. Tax Reform enactment date. In accordance with the Bulletin, as of October 31, 2018, the Company recorded a tax benefit related to the revaluation of deferred tax assets and liabilities of $72.0 million and a provisional tax expense for the one-time transition tax liability of $52.8 million. As a result of additional analysis, as of January 31, 2019, the Company revised its calculation for the one-time transition tax to $55.1 million. Further, in this quarter the provisions of the U.S. Tax Reform Act caused the Company to re-evaluate its permanent reinvestment assertion, concluding that the unremitted earnings and profits of certain non-U.S. subsidiaries and affiliates will no longer be permanently reinvested. These changes in assertion required the recognition of a tax benefit of $1.7 million due to Section 986(c) currency losses. The Company has recognized a total net tax benefit of $18.6 million related to these tax reform items.
The Tax Reform Act also subjects a U.S. shareholder to current tax on global intangible low-taxed income (“GILTI”) earned by certain foreign subsidiaries and allows a benefit for foreign-derived intangible income (“FDII”). These provisions of tax reform are first effective for the Company’s current year. The Company has made sufficient progress in its calculation to reasonably estimate the tax impact related to GILTI and FDII and these estimates are included as period costs in the estimated annual effective tax rate.
We consider the tax expense recorded for the Tax Reform Act to be complete at this time. However, it is possible that additional legislation, regulations and/or guidance may be issued in the future that may result in additional adjustments to the tax expense recorded. We will continue to monitor and assess the impact of any new developments.
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 has 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 three months ended January 31, 2019, income tax expense was $20.0 million; whereas, for the three months ended January 31, 2018 the income tax benefit was $15.6 million. The income tax benefit recorded in the first quarter of 2018 reflected a net tax benefit resulting from the re-measurement of deferred tax assets and liabilities, reduced by the increase in the tax expense related to the one-time transition tax liability.