Note 12 — Income Taxes

The effective tax rate for the three months ended January 31, 2019 was 22.7%, compared to a tax benefit of 18.1% for the three months ended January 31, 2018. The effective tax rate for the nine months ended January 31, 2019 was 22.6% compared to 4.0% in the corresponding prior year period. The rates for the three months and nine months ended January 31, 2019 were higher than the rates for the corresponding prior periods due to the impact of U.S. tax legislation originally known as the Tax Cuts and Jobs Act of 2017 (the “Tax Act”) enacted on December 22, 2017. During the three months and nine months ended January 31, 2018, we recorded a provisional estimated net tax benefit of $25 million. Excluding the effects of this non-recurring item, the rates would have been 24.8% and 21.4% for the three months and nine months ended January 31, 2018, respectively.

The 22.7% rate for the three months ended January 31, 2019 is lower than 24.8% primarily due to the decrease in U.S. statutory tax rate. The 22.6% rate for the nine months ended January 31, 2019 is higher than 21.4%, primarily due to large equity compensation deductions from significant vesting of restricted stock and other one-time adjustments as well as the impact of a relatively high tax benefit on restructuring costs incurred during the nine months ended January 31, 2018, partially offset by the lower U.S. statutory tax rate.

The Tax Act

On December 22, 2017, the U.S. enacted the Tax Act which significantly changed U.S tax law by, among other changes, the following:

lowered the U.S. federal corporate income tax rate from 35% to 21% with a potentially lower rate for certain foreign derived income, while imposing a deemed repatriation tax on previously deferred foreign income.

· created new additional taxes on certain foreign earnings.

We completed our accounting for the income tax effects of the Tax Act during our third quarter of 2019, in accordance with the U.S. Securities and Exchange Commission Staff Accounting Bulletin No. 118 (SAB 118) measurement period.

As mentioned above, the newly created taxes of the Tax Act, effective for us on May 1, 2018, include a provision designed to tax certain global income ("GILTI"), and a base erosion anti-abuse tax ("BEAT") as well as a new deduction for certain foreign derived intangible income (“FDII”). We recorded a minor benefit during the nine months ended January 31, 2019 and we may adjust this amount in connection with our year-end results and as additional guidance is provided.