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Income Taxes
12 Months Ended
Dec. 31, 2022
Income Tax Disclosure [Abstract]  
INCOME TAXES INCOME TAXES
Income tax benefit consists of the following:
Years Ended December 31,Six-month Transition Period Ended December 31,Year Ended June 30,
(in millions)2022202120202020
Current:
Federal$(0.5)$(1.9)$(75.8)$26.6 
State1.9 3.6 (0.6)4.9 
Foreign0.5 0.1 0.2 0.5 
Total current1.9 1.8 (76.2)32.0 
Deferred:
Federal(25.8)(33.7)39.1 (51.5)
State(4.8)5.1 (3.4)(4.1)
Foreign(2.9)0.1 (0.5)(3.6)
Change in valuation allowance3.0 (3.2)— 3.5 
Total deferred(30.5)(31.7)35.2 (55.7)
Total income tax benefit$(28.6)$(29.9)$(41.0)$(23.7)
Loss before income taxes consists of the following:
Years Ended December 31,Six-month Transition Period Ended December 31,Year Ended June 30,
(in millions)2022202120202020
United States$(141.3)$(53.8)$(101.8)$(240.9)
Foreign0.7 (3.3)7.7 17.6 
Total$(140.6)$(57.1)$(94.1)$(223.3)
The differences between income taxes at the statutory federal income tax rate and income taxes reported in the Consolidated Statements of Operations were as follows:
Years Ended December 31,Six-month Transition Period Ended December 31,Year Ended June 30,
(in millions)2022202120202020
Federal income tax expense at the statutory rate$(29.5)21.0 %$(12.0)21.0 %$(19.8)21.0 %$(46.9)21.0 %
State income taxes, net of federal benefit(3.3)2.3 %(1.8)3.2 %(1.2)1.3 %4.0 (1.8)%
Research and development credits(3.5)2.5 %2.5 (4.4)%(1.3)1.4 %(2.8)1.3 %
Uncertain tax positions0.6 (0.4)%(3.0)5.3 %0.6 (0.7)%1.5 (0.7)%
Incentive stock option and employee stock purchase plan expense2.5 (1.8)%0.7 (1.2)%2.5 (2.7)%(0.2)0.1 %
Foreign rate differential— — %0.5 (0.9)%(2.1)2.2 %0.7 (0.3)%
Change in valuation allowance2.6 (1.8)%(3.2)5.6 %(0.3)0.3 %3.5 (1.7)%
CARES Act— — %2.7 (4.7)%(20.7)22.0 %— — %
Non-deductible meals and entertainment— — %0.1 (0.2)%0.5 (0.5)%1.8 (0.8)%
Non-deductible officer compensation3.5 (2.5)%3.3 (5.8)%0.1 (0.1)%1.6 (0.7)%
Asset impairment— — %— — %— — %12.6 (5.6)%
Non-deductible legal settlement— — %2.5 (4.5)%— — %— — %
Acquisitions, dispositions, and contingent consideration(0.1)0.1 %(23.0)40.3 %0.7 (0.7)%(0.3)0.1 %
Other, net(1.4)0.9 %0.8 (1.4)%— — %0.8 (0.3)%
Total income tax benefit$(28.6)20.3 %$(29.9)52.3 %$(41.0)43.5 %$(23.7)10.6 %
The significant components of the Company’s deferred tax assets and liabilities were comprised of the following:
December 31,
(in millions)20222021
Deferred tax assets:
Net operating loss carryforwards$66.6 $67.2 
Deferred revenue0.2 1.2 
Stock compensation expense3.6 4.5 
Research and development credits19.9 17.3 
Lease liability35.2 22.4 
Section 174 capitalized costs21.2 — 
Accrued expenses and liabilities10.8 14.2 
Other, net3.4 4.5 
Total gross deferred tax assets160.9 131.3 
Less valuation allowance(42.4)(38.5)
Total deferred tax assets118.5 92.8 
Deferred tax liabilities:
Intangible assets93.8 104.9 
Lease right-of-use assets25.4 20.2 
Property, plant and equipment2.8 3.5 
Total deferred tax liabilities122.0 128.6 
Net deferred tax liability$(3.5)$(35.8)
The Tax Cuts and Jobs Act (TCJA), passed in 2017, amended Section 174 of the Internal Revenue Code to require that specific research and experimental (R&E) expenditures be capitalized and amortized over five years for U.S. R&E expenditures or 15 years for non-US R&E expenditures beginning in the Company’s fiscal year ended December 31, 2022. Although Congress has considered legislation that would defer, modify or repeal the capitalization and amortization requirement, there is no assurance that the provision will be deferred, repealed or otherwise modified. If the requirement is not modified, the Company may be required to utilize some of its federal and state tax attributes and there may be increases to state cash taxes or tax expense.
The Company has incurred a cumulative three-year loss. Pursuant to ASC 740, Income Taxes, the negative evidence of a cumulative loss may be difficult to overcome. However, the Company will have significant future taxable income resulting from the reversal of taxable temporary differences. Primarily due to the availability of such expected future taxable income, the Company concluded that it is more likely than not that the benefits of the majority of its deferred income tax assets will be realized. However, for certain deferred tax assets a valuation allowance has been established, primarily due to limitations imposed by Section 382 of the Internal Revenue Code and certain jurisdictional limitations. For the year ended December 31, 2022, the Company's valuation allowance increased by $3.9 million, primarily due to the anticipated inability to utilize deferred tax assets related to state attributes and credits.
At December 31, 2022, the Company had the following net operating loss and research credit carryforwards (tax effected), with their respective expiration periods. Certain carryforwards are subject to the limitations of Section 382 and 383 of the Internal Revenue Code as indicated (in millions):
CarryforwardsAmountSubject to
sections 382, 383
Expires
beginning in year
Through
Federal net operating loss$26.6 Yes2033Indefinite
Federal capital loss13.5 No 20262026
Utah net operating loss2.8 No2023Indefinite
California net operating loss4.4 Yes20292041
Other state net operating loss7.7 YesVariousVarious
Foreign net operating losses (various jurisdictions)11.6 NoVariousVarious
Federal research credit8.7 Yes20272042
Utah research credit6.9 No20232036
California research credit4.4 NoIndefiniteIndefinite
Due to the cumulative losses that have been incurred to date in foreign operations, the changes of the Tax Cuts and Jobs Act and the election to treat its foreign subsidiaries as disregarded entities, no deferred taxes related to the Company’s foreign operations have been recorded. For those foreign entities for which an election has been made to be treated as disregarded for U.S. tax purposes, the appropriate U.S. jurisdiction deferred tax assets and liabilities have been recorded. 
The Company provides for uncertain tax positions when such tax positions do not meet the recognition thresholds or measurement criteria as set forth in ASC 740. As of December 31, 2022, the Company had net unrecognized tax benefits of $31.9 million. The Company’s gross unrecognized tax benefits as of the years ended December 31, 2022 and 2021, the transition period ended December 31, 2020 and the fiscal year ended June 30, 2020, and the changes in those balances are as follows: 
Years Ended December 31,Six-month Transition Period Ended December 31,Year Ended June 30,
(in millions)2022202120202020
Unrecognized tax benefits at the beginning of period$32.1 $37.6 $23.5 $21.7 
Gross increases - current year tax positions0.9 1.4 13.9 1.6 
Gross increases - prior year tax positions1.6 1.1 1.0 0.7 
Gross decreases - prior year tax positions(2.0)(2.8)(0.1)— 
Gross decreases - settlements(0.7)(5.1)— — 
Gross decreases - statute lapse— (0.1)(0.7)(0.5)
Unrecognized tax benefits at end of year$31.9 $32.1 $37.6 $23.5 
Interest and penalties in year-end balance$4.1 $3.3 $2.2 $1.4 
Interest and penalties related to uncertain tax positions are included as a component of Income tax benefit and all other interest and penalties are included as a component of Other income (expense) in the Consolidated Statements of Operations.
The Company files U.S. federal, foreign and state income tax returns in jurisdictions with various statutes of limitations. The Company is currently under audit by the state of California for years ended June 30, 2017 and 2018.  Annual tax provisions include amounts considered necessary to pay assessments that may result from examination of prior year tax returns; however, the amount ultimately paid upon resolution of issues may differ materially from the amount accrued.