13. Income Taxes

The components of income (loss) before (provision) benefit for income taxes are as follows (in thousands):

	Fiscal Year		Fiscal Year		Fiscal Year
	2015 (52 weeks)		2014 (53 weeks)		2013 (52 weeks)
Income before (provision) benefit for income taxes:
U.S.	$	10,565	$	20,899	$	13,659
Foreign		1,250		2,416		4,259

Total	$	11,815	$	23,315	$	17,918

The provision (benefit) for income taxes consists of the following (in thousands):

	Fiscal Year			Fiscal Year			Fiscal Year
	2015 (52 weeks)			2014 (53 weeks)			2013 (52 weeks)
Currently payable:
Federal	$	5,104		$	8,585		$	1,241
Foreign		546			876			1,264
State		1,550			1,878			254

		7,200			11,339			2,759
Deferred:
Federal		(799	)		(1,068	)		3,592
Foreign		(307	)		(505	)		(238	)
State		(604	)		142			570

	$	(1,710	)	$	(1,431	)	$	3,924

	$	5,490		$	9,908		$	6,683

A reconciliation of CRA's tax rates with the Federal statutory rate is as follows:

	Fiscal Year			Fiscal Year			Fiscal Year
	2015			2014			2013
Federal statutory rate		35.0	%		35.0	%		35.0	%
State income taxes, net of federal income tax benefit		9.2			3.6			4.4
State law changes		(3.8	)		—			—
Foreign losses benefited		(9.2	)		(1.8	)		(2.8	)
Losses not benefited		5.0			0.6			0.3
Foreign rate differential		(2.7	)		0.6			(0.4	)
Foreign tax credit		—			—			(0.1	)
Uncertain tax positions		8.7			0.7			(2.1	)
NeuCo goodwill impairment		13.4			—			—
NeuCo tax provision (benefit)		(13.6	)		0.9			1.5
Permanently disallowed expenses		6.8			2.1			1.6
Prior period adjustments		(0.6	)		3.0			—
Release of valuation allowance		(1.7	)		(2.2	)		—
Other		—			—			(0.1	)

		46.5	%		42.5	%		37.3	%

The components of CRA's deferred tax assets (liabilities) are as follows (in thousands):

	January 2, 2016			January 3, 2015
Deferred tax assets:
Accrued compensation and related expense	$	25,148		$	23,876
Allowance for doubtful accounts		2,159			2,065
Net operating loss carryforwards		4,097			5,201
Accrued expenses and other		2,462			967

Total gross deferred tax assets		33,866			32,109
Less: valuation allowance		(4,003	)		(4,912	)

Total deferred tax assets net of valuation allowance		29,863			27,197
Deferred tax liabilities:
Goodwill and other intangible asset amortization		4,715			5,191
Property and equipment		3,723			498
Tax basis in excess of financial basis of debentures		2,569			3,844

Total deferred tax liabilities		11,007			9,533

Net deferred tax assets	$	18,856		$	17,664

The net change in the total valuation allowance for fiscal 2015 was a decrease of approximately $0.9 million compared to fiscal 2014. The $0.9 million net decrease is comprised primarily of benefits realized for the use of net operating loss carryforwards related to current and prior year taxable income as well as a release of valuation allowance, and reduction for reserve items. This is offset partially by an additional valuation allowance recorded against NeuCo's net deferred tax assets and liabilities.

At January 2, 2016 CRA had $3.9 million of foreign net operating loss carry forwards. The foreign operating losses have an indefinite life, except for $0.2 million that will begin to expire in fiscal 2017. NeuCo has federal, state, and foreign net operating losses of $8.6 million, $3.9 million, and $0.1 million, respectively, which are subject to a full valuation allowance and begin to expire in 2016. NeuCo files separate tax returns and none of its losses are available to offset CRA's consolidated taxable income.

The aggregate changes in the balances of gross unrecognized tax benefits were as follows (in thousands):

	January 2, 2016			January 3, 2015
Balance at beginning of period	$	535		$	372
Additions for tax positions taken during prior years		—			127
Additions for tax positions taken during the current year		892			45
Settlements with tax authorities		(162	)		(9	)

Balance at end of the period	$	1,265		$	535

CRA files income tax returns in the U.S. federal jurisdiction and various state and foreign jurisdictions. A number of years may elapse before an uncertain tax position, for which CRA has unrecognized tax benefits, is audited and finally resolved. While it is often difficult to predict the final outcome or the timing of resolution of any particular uncertain tax position, CRA believes that its unrecognized tax benefits reflect the most likely outcome. CRA adjusts these unrecognized tax benefits, and the associated interest, in light of changing facts and circumstances. At the end of fiscal 2015, CRA had $91,000 of interest accrued on its unrecognized tax benefit balance for a total unrecognized tax benefit balance on the balance sheet of $1,356,000. Of the total unrecognized tax benefit balance, $86,000 is offset by a future tax deduction when recognized. CRA reported $18,000 of interest and penalties related to unrecognized tax benefits in income tax expense during fiscal 2015 as compared to $85,000 during fiscal 2014. Settlement of any particular position could require the use of cash. Of the total $1,265,000 balance at the end of fiscal 2015, a favorable resolution would result in $855,000 being recognized as a reduction to the effective income tax rate in the period of resolution. It is reasonably likely that $195,000 of gross unrecognized tax benefits will reverse within the next twelve months.

The number of years with open tax audits varies depending on the tax jurisdiction. CRA's major taxing jurisdiction is the United States where we are no longer subject to U.S. federal examinations by the Internal Revenue Service for years before fiscal 2012. Within the significant states where CRA is subject to income tax, CRA is no longer subject to examinations by state taxing authorities before fiscal 2011. CRA's United Kingdom subsidiary's corporate tax returns are no longer subject to examination by Her Majesty's Revenue and Customs for fiscal years before fiscal 2011. During this fiscal year, 2015, CRA has concluded the examinations in France for fiscal 2011 and fiscal 2012, and CRA has effectively settled the examination in Germany for fiscal 2008 through 2011. CRA believes its reserves for uncertain tax positions are adequate.

CRA has not provided for deferred income taxes or foreign withholding taxes on undistributed earnings from its foreign subsidiaries of approximately $3.4 million as of January 2, 2016 because such earnings are considered to be indefinitely reinvested. CRA does not rely on these unremitted earnings as a source of funds for its domestic business as it expects to have sufficient cash flow in the U.S. to fund its U.S. operational and strategic needs. If CRA were to repatriate its foreign earnings that are indefinitely reinvested, it would accrue substantially no additional tax expense.