Income Taxes

On December 22, 2017, the Tax Cuts and Jobs Act (the “Act”) was signed into law in the United States. The effects of the Act included the reduction of the federal corporate income tax rate from 35 percent to 21 percent and a new participation exemption system of taxation on foreign earnings, among other provisions.

In accordance with Staff Accounting Bulletin 118, for the year ended June 2, 2018, the Company recorded a provisional tax benefit of $3.1 million from the impact of the Act, primarily related to the one-time U.S. tax liability on certain undistributed foreign earnings and the remeasurement of current and deferred tax liabilities. Subsequently, as the U.S. Treasury Department issued additional guidance, the Company recorded adjustments to the provisional tax benefit. During the year ended June 1, 2019, the Company completed its accounting for all the effects of the Act and recorded adjustments to the provisional amounts primarily for the one-time U.S. tax liability on certain undistributed foreign earnings and also an adjustment related to foreign tax credits to increase the income tax benefit from the Act by $1.0 million.

The U.S. Treasury Department and the Internal Revenue Service are expected to continue issuing additional guidance related to the Act, which could have a material impact to the provision for income taxes. If applicable, the Company would recognize any adjustments in the provision for income taxes in the period additional guidance is issued.

For tax years beginning after December 31, 2017, the Act subjects a U.S. shareholder to tax on global intangible low-taxed income (“GILTI”) earned by certain foreign subsidiaries. The FASB Staff Q&A, Topic 740, No. 5, Accounting for Global Intangible Low-Taxed Income, states that an entity can make an accounting policy election to either recognize deferred taxes for temporary basis differences expected to reverse as GILTI in future years or provide for the tax expense related to GILTI in the year the tax is incurred. The Company will account for tax expense related to GILTI in the year the tax is incurred.

The components of earnings before income taxes are as follows:



(In millions)	2019		2018		2017
Domestic	$	136.2	$	121.6	$	131.4
Foreign	58.9		46.5		46.2
Total	$	195.1	$	168.1	$	177.6

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



(In millions)	2019			2018			2017
Current: Domestic - Federal	$	19.0		$	30.2		$	28.7
Domestic - State	6.4			4.3			2.3
Foreign	12.9			10.7			11.1
	38.3			45.2			42.1
Deferred: Domestic - Federal	1.0			(4.1		)	9.2
Domestic - State	(0.2		)	0.1			2.8
Foreign	0.5			1.2			1.0
	1.3			(2.8		)	13.0
Total income tax provision	$	39.6		$	42.4		$	55.1

The following table represents a reconciliation of income taxes at the United States statutory rate of 21% for 2019, 29.1% for 2018, and 35% for 2017 with the effective tax rate as follows:



(In millions)	2019			2018			2017
Income taxes computed at the United States Statutory rate	$	41.0		$	49.0		$	62.2
Increase (decrease) in taxes resulting from:
Remeasurement of U.S. deferred tax assets and liabilities due to the Tax Act	(0.2		)	(8.9		)	—
U.S. tax liability on undistributed foreign earnings due to the Tax Act	(2.6		)	9.0			—
Foreign-derived intangible income	(3.1		)	—			—
Global intangible low-taxed income	6.9			—			—
Foreign statutory rate differences	1.9			(4.0		)	(5.7		)
Manufacturing deduction under the American Jobs Creation Act of 2004	—			(2.7		)	(3.4		)
State taxes	4.9			3.3			3.8
United Kingdom patent box deduction for research and development	(1.9		)	(1.8		)	(2.6		)
Research and development credit	(3.4		)	(2.4		)	(1.4		)
Foreign tax credit	(5.7		)	(2.4		)	(0.6		)
Other, net	1.8			3.3			2.8
Income tax expense	$	39.6		$	42.4		$	55.1
Effective tax rate	20.3		%	25.2		%	31.1		%

The tax effects and types of temporary differences that give rise to significant components of the deferred tax assets and liabilities at June 1, 2019 and June 2, 2018, are as follows:



(In millions)	2019			2018
Deferred tax assets:
Compensation-related accruals	$	13.1		$	15.3
Accrued pension and post-retirement benefit obligations	7.2			6.6
Deferred revenue	6.1			5.6
Inventory related	1.2			1.0
Reserves for uncollectible accounts and notes receivable	0.7			0.6
Other reserves and accruals	8.1			5.2
Warranty	12.3			11.9
State and local tax net operating loss carryforwards and credits	2.5			2.3
Federal net operating loss carryforward	1.4			1.7
Foreign tax net operating loss carryforwards and credits	9.1			10.0
Accrued step rent and tenant reimbursements	4.2			3.8
Other	4.0			3.9
Subtotal	69.9			67.9
Valuation allowance	(10.4		)	(10.3		)
Total	$	59.5		$	57.6

Deferred tax liabilities:
Book basis in property in excess of tax basis	$	(26.6	)	$	(25.5	)
Intangible assets	(34.6		)	(32.3		)
Other	(2.1		)	(6.9		)
Total	$	(63.3	)	$	(64.7	)

The future tax benefits of net operating loss (NOL) carry-forwards and foreign tax credits are recognized to the extent that realization of these benefits is considered more likely than not. The Company bases this determination on the expectation that related operations will be sufficiently profitable or various tax planning strategies will enable the Company to utilize the NOL carry-forwards and/or foreign tax credits. To the extent that available evidence about the future raises doubt about the realization of these tax benefits, a valuation allowance is established.

At June 1, 2019, the Company had state and local tax NOL carry-forwards of $25.7 million, the state tax benefit of which is $1.4 million, which have various expiration periods from 1 to 21 years. The Company also had state credits with a state tax benefit of $1.1 million, which expire in 1 to 6 years. For financial statement purposes, the NOL carry-forwards and state tax credits have been recognized as deferred tax assets, subject to a valuation allowance of $1.3 million.

At June 1, 2019, the Company had federal NOL carry-forwards of $6.6 million, the tax benefit of which is $1.4 million, which expire in 10 years. For financial statement purposes, the NOL carry-forwards have been recognized as deferred tax assets.

At June 1, 2019, the Company had federal deferred assets of $2.2 million, the tax benefit of which is $0.5 million, which is related to investments in various foreign joint ventures. For financial statement purposes, the assets have been recognized as deferred tax assets, subject to a valuation allowance of $0.5 million.

At June 1, 2019, the Company had foreign net operating loss carry-forwards of $41.2 million, the tax benefit of which is $9.1 million, which have expiration periods from 9 years to an unlimited term. For financial statement purposes, the NOL carry-forwards have been recognized as deferred tax assets, subject to a valuation allowance of $7.6 million.

At June 1, 2019, the Company had foreign deferred assets of $5.5 million, the tax benefit of which is $1.0 million, which is related to various deferred taxes in Hong Kong and Brazil as well as buildings in the United Kingdom. For financial statement purposes, the assets have been recognized as deferred tax assets, subject to a valuation allowance of $1.0 million.

The Company has recorded transition tax on undistributed foreign earnings as required by the Act. No other provision was made for income taxes that may result from future remittances of the undistributed earnings of foreign subsidiaries that are determined to be indefinitely reinvested, which was $223.8 million on June 1, 2019. Determination of the total amount of unrecognized deferred income tax on undistributed earnings of foreign subsidiaries is not practicable.

The components of the Company's unrecognized tax benefits are as follows:



(In millions)
Balance at June 3, 2017	$	2.8
Increases related to current year income tax positions	0.3
Increases related to prior year income tax positions	0.4
Decreases related to lapse of applicable statute of limitations	(0.3		)
Balance at June 2, 2018	$	3.2
Increases related to current year income tax positions	0.4
Increases related to prior year income tax positions	0.1
Decreases related to prior year income tax positions	(0.4		)
Decreases related to lapse of applicable statute of limitations	(0.3		)
Decreases related to settlements	(1.1		)
Balance at June 1, 2019	$	1.9

The Company's effective tax rate would have been affected by the total amount of unrecognized tax benefits had this amount been recognized as a reduction to income tax expense.

The Company recognizes interest and penalties related to unrecognized tax benefits through Income tax expense in its Consolidated Statements of Comprehensive Income. Interest and penalties and the related liability, which are excluded from the table above, were as follows for the periods indicated:



(In millions)	June 1, 2019			June 2, 2018		June 3, 2017
Interest and penalty expense (income)	$	(0.3	)	$	0.1	$	0.2
Liability for interest and penalties	$	0.7		$	1.0

The Company is subject to periodic audits by domestic and foreign tax authorities. Currently, the Company is undergoing routine periodic audits in both domestic and foreign tax jurisdictions. It is reasonably possible that the amounts of unrecognized tax benefits could change in the next 12 months as a result of new positions that may be taken on income tax returns, settlement of tax positions and the closing of statutes of limitation. It is not expected that any of the changes will be material to the Company's Consolidated Statements of Comprehensive Income.

During the year, the Company has partially closed the audit of fiscal 2018 with the Internal Revenue Service under the Compliance Assurance Process (CAP). For the majority of the remaining tax jurisdictions, the Company is no longer subject to state and local, or non-U.S. income tax examinations by tax authorities for fiscal years before 2016.