On March 27, 2020, the Coronavirus Aid, Relief and Economic Security, or CARES, Act was enacted and signed into law. The CARES Act did not have a material impact on the income tax provision for the fiscal year ended June 26, 2021.

Income/(loss) before provision for income taxes for fiscal 2021, 2020, and 2019 consisted of the following (in millions):

	2021			2020			2019
United States	$	(21.0	)	$	(13.5	)	$	(40.6	)
Foreign		141.1			172.9			19.8
Income/(loss) before provision for income taxes	$	120.1		$	159.4		$	(20.8	)

The provision for income taxes for fiscal 2021, 2020, and 2019 consisted of the following (in millions):

	2021			2020			2019
Current tax expense/(benefit)
Federal	$	4.1		$	0.8		$	(4.9	)
State		0.1			—			—
Foreign		36.1			35.4			20.4
		40.3			36.2			15.5
Deferred tax expense/(benefit)
Federal		(0.5	)		(5.8	)		(8.5	)
State		-			0.1			—
Foreign		(8.4	)		8.1			(6.7	)
		(8.9	)		2.4			(15.2	)
Provision for income taxes	$	31.4		$	38.6		$	0.3

The provision for income taxes differs from the federal statutory rate for fiscal 2021, 2020, and 2019 as follows (in millions):

	2021			2020			2019
Provision at U.S. federal statutory tax rate	$	25.1		$	33.5		$	(4.4	)
State income taxes		0.1			—			—
Non-deductible share-based compensation		5.2			3.0			4.0
(Windfall)/shortfall related to share-based compensation		(3.8	)		2.1			3.3
Non-deductible officer compensation		6.4			1.9			1.1
Business credits		(3.8	)		(6.1	)		(6.1	)
Foreign tax differential		(6.7	)		4.9			1.0
Nondeductible amortization		—			—			0.7
Foreign income inclusion		5.2			0.7			0.4
Deferred taxes on unremitted foreign earnings		3.5			—			—
Other differences		0.2			(1.4	)		0.3
Provision for income taxes	$	31.4		$	38.6		$	0.3

Net deferred tax assets of $1.2 million and $28.7 million were non-current as of the end of fiscal 2021 and 2020, respectively, and were included in other assets in the accompanying consolidated balance sheets.

Significant components of our deferred tax assets (liabilities) as of the end of fiscal 2021 and 2020 consisted of the following (in millions):

	2021			2020
Deferred tax assets:
Capital loss carryforward	$	0.2		$	—
Inventory write downs		3.9			4.0
Property and equipment		—			1.2
Accrued compensation		0.3			3.4
Deferred compensation		0.8			0.6
Share-based compensation		8.8			6.8
Business credit carryforward		39.1			41.3
Acquisition intangibles		6.0			6.6
Net operating loss carryforward		7.2			—
Other accruals		4.3			5.2
		70.6			69.1
Valuation allowance		(32.6	)		(33.3	)
		38.0			35.8
Deferred tax liabilities:
Property and equipment		(0.9	)		—
Interest		(3.4	)		(7.1	)
Unremitted foreign earnings		(3.5	)		—
Acquisition intangibles		(29.0	)		—
		(36.8	)		(7.1	)
Net deferred tax assets	$	1.2		$	28.7

Realization of deferred tax assets depends on our generating sufficient U.S. and certain foreign taxable income in future years to obtain a benefit from the utilization of those deferred tax assets on our tax returns. Accordingly, the amount of deferred tax assets considered realizable may increase or decrease when we reevaluate the underlying basis for our estimates of future U.S. and foreign taxable income. As of the end of fiscal 2021, a valuation allowance of $32.6 million was maintained to reduce deferred tax assets to levels we believe are more likely than not to be realized through future taxable income. The net change in the valuation allowance during fiscal 2021 was a decrease of $0.7 million.

We assessed our current and future liquidity in the fourth quarter of fiscal 2021 and determined not to permanently reinvest earnings of certain foreign jurisdictions. As a result of our determination, we recorded $3.5 million of deferred tax liability. We continue to indefinitely reinvest $2.1 million of accumulated earnings.

As of the end of fiscal 2021, we had federal, California, and foreign net operating loss carryforwards of approximately $0.5 million, $4.8 million, and $30.6 million, respectively. The California net operating loss will begin to expire in fiscal 2033, if not utilized. Under current tax law, net operating loss and tax credit carryforwards available to offset future income or income taxes may be limited by statute or upon the occurrence of certain events, including significant changes in ownership.

We had $16.2 million and $47.0 million of federal and state research tax credit carryforwards, respectively, as of the end of fiscal 2021. The federal research tax credit carryforward will begin to expire in 2038 and the state research tax credit can be carried forward indefinitely.

The total liability for gross unrecognized tax benefits related to uncertain tax positions, included in other liabilities in our consolidated balance sheets, increased by $2.5 million from $20.1 million in fiscal 2020 to $22.6 million in fiscal 2021. Of this amount, $14.3 million will reduce the effective tax rate on income from continuing operations, if recognized. A reconciliation of the beginning and ending balance of gross unrecognized tax benefits for fiscal 2021, 2020, and 2019 consisted of the following (in millions):

	2021			2020			2019
Beginning balance	$	20.1		$	18.9		$	24.8
Increase in unrecognized tax benefits related to current year tax positions		5.5			3.2			4.2
Increase in unrecognized tax benefits related to prior year tax positions		—			0.1			—
Decrease due to effective settlement with tax authorities		—			—			(6.2	)
Remeasurement of unrecognized tax benefits		—			—			(2.0	)
Decrease due to statute expiration		(3.0	)		(2.1	)		(1.9	)
Ending Balance	$	22.6		$	20.1		$	18.9

Accrued interest and penalties decreased by $0.2 million in fiscal 2021 as compared to fiscal 2020 and increased by $0.7 million representing income tax expense in fiscal 2019 as compared to fiscal 2018. Accrued interest and penalties were $1.7 million and $1.9 million as of June 26, 2021 and June 27, 2020, respectively. Our policy is to classify interest and penalties, if any, as components of income tax expense.

It is reasonably possible that the amount of liability for unrecognized tax benefits may change within the next 12 months; an estimate of the range of possible changes could result in a decrease of $3.4 million to an increase of $3.0 million. Any prospective adjustments to our unrecognized tax benefits will be recorded as an increase or decrease to income tax expense and cause a corresponding change to our effective tax rate. Accordingly, our effective tax rate could fluctuate materially from period to period.

Our major tax jurisdictions are the U.S., Hong Kong SAR, Japan and the U.K. From fiscal 2014 onward, we remain subject to examination by one or more of these jurisdictions.