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Income Taxes
 6 Months Ended
Apr. 01, 2012
Income Taxes [Abstract]  
Income Taxes

(11) Income Taxes

For the three and six months ended April 1, 2012, the Company’s effective tax rates of 101% and 55%, respectively, were higher than the United States Federal statutory rate of 35% primarily as a result of: (i) deferred income tax expense due to changes in the tax bases of indefinite lived intangible assets that are amortized for tax purposes, but not for book purposes, (ii) pretax losses in the United States and some foreign jurisdictions for which the Company concluded that the tax benefits are not more-likely-than-not realizable and (iii) tax expense on income in certain foreign jurisdictions that will not be creditable in the United States. Partially offsetting these factors was: (i) a $19,035 release by FGL in the three and six month periods of valuation allowances on deferred tax assets primarily as a result of revised projections in connection with the regulatory non-approval of a proposed reinsurance transaction, (ii) a $41,000 gain in the three and six month periods on a contingent purchase price reduction receivable for which no tax provision is necessary and (iii) a $13,915 release by Spectrum Brands in the six month period of valuation allowances on deferred tax assets as a result of a recent acquisition. Net operating loss (“NOL”) and tax credit carryforwards of HGI and Spectrum Brands are subject to full valuation allowances as the Company concluded the associated tax benefits are not more-likely-than-not realizable. Utilization of NOL and other tax carryforwards of HGI, Spectrum Brands and FGL are subject to limitations under Internal Revenue Code (“IRC”) Sections 382 and 383. Such limitations result from ownership changes of more than 50 percentage points over a three-year period.

For the three and six months ended April 3, 2011, the Company’s effective tax rates were (42)% and (112)%, respectively. Despite consolidated pretax losses, income tax expense was recorded in these periods primarily as a result of: (i) deferred income tax expense due to changes in the tax bases of indefinite lived intangible assets that are amortized for tax purposes, but not for book purposes, (ii) pretax losses in the United States and some foreign jurisdictions for which the Company concluded that the tax benefits are not more- likely-than-not realizable and (iii) tax expense on income in certain foreign jurisdictions that will not be creditable in the United States.

The Company recognizes in its consolidated financial statements the impact of a tax position if it concludes that the position is more likely than not sustainable upon audit based on the technical merits of the position. At April 1, 2012 and September 30, 2011, the Company had $6,277 and $9,013, respectively, of unrecognized tax benefits on uncertain tax positions. The Company also had approximately $4,431 and $4,682, respectively of accrued interest and penalties related to the uncertain tax positions at those dates. Interest and penalties related to uncertain tax positions are reported in the financial statements as part of income tax expense. The Company does not expect its balance of unrecognized tax benefits at April 1, 2012 to materially change over the next twelve months.