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Income Taxes
 9 Months Ended
Jul. 01, 2012
Income Taxes [Abstract]  
Income Taxes

(11) Income Taxes

For the three months ended July 1, 2012, the Company’s tax benefit at an effective rate of 5% was lower than the United States Federal statutory rate of 35% and, for the nine months ended July 1, 2012, the Company recorded tax expense at the rate of (355)% despite a pretax loss, primarily as a result of (i) $125,540 of expense in the three-month period for the increase in fair value of the equity conversion feature of preferred stock, for which no tax benefit is available, (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, (iii) 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, and (iv) tax expense on income in certain foreign jurisdictions that will not be creditable in the United States. Partially offsetting these factors in the nine months ended July 1, 2012 was (i) a $19,035 release by FGL 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 on a contingent purchase price reduction receivable, for which no tax provision is necessary, and (iii) a $13,915 release by Spectrum Brands 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 and those of FGL are subject to partial valuation allowances, as the Company concluded all or a portion of 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 months ended July 3, 2011, the Company’s effective tax rate of 2% was lower than the United States Federal statutory rate principally due to (i) the recognition of a $158,341 bargain purchase gain from the FGL Acquisition, for which no tax provision is necessary, and (ii) the release of valuation allowances on tax benefits from net operating and capital loss carryforwards that the Company determined are more-likely-than-not realizable. In addition to these factors, the Company’s effective tax rate for the nine months ended July 3, 2011 of 35% reflects the proportionally higher offsetting effects 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, and (ii) 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 July 1, 2012 and September 30, 2011, the Company had $5,379 and $9,013, respectively, of unrecognized tax benefits on uncertain tax positions. The Company also had approximately $4,180 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 July 1, 2012 to materially change over the next twelve months.