v3.10.0.1
INCOME TAXES
6 Months Ended
Jun. 30, 2018
Income Taxes  
INCOME TAXES
NOTE 8:-        INCOME TAXES

a.
Taxes on income (tax benefit) are comprised as follows:

   
Three months ended
June 30,
   
Six months ended
June 30,
 
   
2018
   
2017
   
2018
   
2017
 
   
(unaudited)
   
(unaudited)
 
                         
Current year taxes
 
$
5,314
   
$
959
   
$
12,297
   
$
2,028
 
Deferred tax income net, and others
   
(1,697
)
   
(773
)
   
(3,018
)
   
(2,603
)
                                 
Taxes on income (tax benefit)
 
$
3,617
   
$
186
   
$
9,279
   
$
(575
)
 
b.
Deferred income taxes:

Deferred income taxes reflect the net tax effect of temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for income tax purposes.

Significant components of the Company’s deferred tax liabilities and assets are as follows:

   
June 30,
   
December 31,
 
   
2018
   
2017
 
   
(Unaudited)
       
             
Net assets in respect of:
           
             
Research and Development carryforward expenses- temporary differences
 
$
7,229
   
$
5,380
 
Stock based compensation
   
2,093
     
1,622
 
Allowances, provisions and others
   
2,229
     
1,338
 
                 
Net deferred tax assets
 
$
11,551
   
$
8,340
 

c.
Uncertain tax positions:

As of June 30, 2018, the Company recognized a total liability for uncertain tax positions in an immaterial amount.

d.
On December 22, 2017, the Tax Cuts and Jobs Act (the "TCJA") was signed into law making significant changes to U.S. income tax law. These changes include, but are not limited to, a corporate tax rate decrease from 35% to 21% effective for tax years beginning after December 31, 2017, the transition of U.S. international taxation from a worldwide tax system to a territorial system, and a one-time transition tax on the mandatory deemed repatriation of cumulative foreign earnings (the “E&P”) as of December 31, 2017.

During the fourth quarter of 2017, the Company calculated its best estimate of the impact of the TCJA in its year end income tax provision in accordance with its understanding of the TCJA and guidance available as of the date of this filing and as a result recorded $19.2 million as an additional income tax expense in the fourth quarter of 2017, the period in which the legislation was enacted.

The provisional amount related to the remeasurement of certain deferred tax assets and liabilities based on the rates at which they are expected to reverse in the future was $0.5 million. The provisional amount related to the one-time transition tax on the mandatory deemed repatriation of foreign earnings was $18.7 million based on cumulative foreign earnings of $145 million. An additional provisional charge of $0.8 million was recorded in the first quarter of 2018 as a result of IRS guidance issued in January.

Additionally, the TCJA requires certain Global Intangible Low Taxed Income (“GILTI”) earned by controlled foreign corporations (“CFCs”) to be included in the gross income of the CFCs’ U.S. shareholder.  GAAP allows the Company to either: (i) treat taxes due on future U.S. inclusions in taxable income related to GILTI as a current-period expense when incurred (the “period cost method”); or (ii) factor such amounts into its measurement of deferred taxes (the “deferred method”).  Effective the first quarter of 2018, the Company elected to treat any potential GILTI inclusions as a period cost, as we are not projecting any material impact from GILTI inclusions and any deferred taxes related to any inclusion would be immaterial.
 
The Company has calculated its best estimate of the impact of the GILTI income tax provision in accordance with its understanding of the TCJA and guidance available as of the date of this filing, and as a result has recorded $3.9 million as an additional income tax expense for the six month ended June 30, 2018.

The final impact of the U.S. tax reform may differ, possibly materially, due to factors such as changes in interpretations and assumptions that the Company has made in its assessment, conclusion of the effects of the GILTI provisions, further refinement of the Company’s calculations, and additional guidance that may be issued by the U.S. government.

As these various factors are finalized, any change will be recorded as an adjustment to the provision for, or benefit from, income taxes in the period in which the amounts are determined, not to exceed 12 months from the date of enactment of the TCJA. The Company has not completed its assessment and the tax charge remains provisional as of June 30, 2018.