10. Income Taxes

The Company files federal income tax returns, as well as multiple state, local and foreign jurisdiction tax returns. A number of years may elapse before an uncertain tax position is audited and finally resolved. While it is often difficult to predict the final outcome or the timing of resolution on any particular uncertain tax position, the Company believes that its reserves for income taxes reflect the most probable outcome. The Company adjusts these reserves, as well as the related interest, in light of changing facts and circumstances. The resolution of a matter would be recognized as an adjustment to the provision for income taxes and the effective tax rate in the period of resolution. The Company is no longer subject to examinations of its federal income tax returns by the Internal Revenue Service for years through 2009 and all significant state, local and foreign matters have been concluded for years
through 2009.

The components of income before income taxes are as follows (in thousands):


	Year Ended
	December 27, 2013	December 28, 2012	December 30, 2011
Domestic	$ 15,823	$ 15,269	$ 15,999
Foreign	(696)	950	1,275
Income before income taxes	$ 15,127	$ 16,219	$ 17,274

The components of income tax expense (benefit) are as follows (in thousands):


	Year Ended
	December 27, 2013	December 28, 2012	December 30, 2011
Current tax expense (benefit)
Federal	$ 10	$ (314)	$ 32
State	530	961	484
Foreign	103	66	246
	643	713	762
Deferred tax expense (benefit)
Federal	6,450	4,532	(5,257)
State	394	(3,587)	-
Foreign	(1,089)	(2,136)	-
	5,755	(1,191)	(5,257)
Income tax expense (benefit)	$ 6,398	$ (478)	$ (4,495)

The income tax benefits in 2012 and 2011 included the release of valuation allowance of $6.7 million and $5.3 million, respectively.

A reconciliation of the federal statutory tax rate with the effective tax rate is as follows:


	Year Ended
	December 27, 2013		December 28, 2012		December 30, 2011
U.S statutory income tax expense rate	35.0	%	35.0	%	35.0	%
State income taxes, net of federal income tax expense	4.0		8.0		1.8
Valuation reduction	(0.5)		(47.7)		(69.3)
Meals and entertainment	1.7		1.5		1.3
Foreign exchange loss	0.4		0.1		0.9
Other, net	1.7		0.1		4.3
Effective tax rate	42.3	%	(3.0)	%	(26.0)	%

The components of the net deferred income tax asset (liability) are as follows (in thousands):


	Year Ended
	December 27, 2013	December 28, 2012
Deferred income tax assets:
Allowance for doubtful accounts	$ 661	$ 521
Net operating loss and tax credits carryforward	12,855	18,423
Accrued expenses and other liabilities	3,967	2,759
	17,483	21,703
Valuation allowance	(1,569)	(1,624)
	15,914	20,079
Deferred income tax liabilities:
Depreciation and amortization	(4,614)	(4,153)
Tax over book amortization on goodwill	(10,546)	(9,470)
Other items	(11)	(5)
	(15,171)	(13,628)
Net deferred income tax asset (liability)	$ 743	$ 6,451

As of December 27, 2013, the Company had $16.5 million of U.S. federal net operating loss carryforwards available for tax purposes, primarily resulting from a worthless stock deduction taken in 2002, most of which will expire by 2022 if not utilized. As of December 27, 2013, the Company had $3.1 million of U.S. state net operating loss carryforwards. Additionally, at December 27,2013, the Company had $20.2 million of foreign net operating loss carryforwards, of which $15.2 million related to operations in the U.K., $1.4 million related to operations in France and $0.7 million related to operations in Germany. A significant amount of the foreign net operating losses may be carried forward indefinitely.

The liability method of accounting for deferred income taxes requires a valuation allowance against deferred tax assets if, based on the weight of available evidence, it is more likely than not that some or all of the deferred tax assets will not be realized. In determining the need for valuation allowances the Company considers evidence such as history of losses and general economic conditions. At both December 27, 2013 and December 28, 2012, the Company had a valuation allowance of $1.6 million to reduce deferred income tax assets primarily related to foreign and state net operating loss and tax credit carryforwards.

The undistributed earnings in foreign subsidiaries are permanently invested abroad and will not be repatriated to the U.S. in the foreseeable future. Because they are considered to be indefinitely reinvested, no U.S. federal or state deferred income taxes have been provided on these earnings. Upon distribution of those earnings, in the form of dividends or otherwise, the Company would be subject to both U.S. income taxes (subject to an adjustment for foreign tax credits) and withholding taxes payable to the various foreign countries in which it operates. Because of the availability of U.S. foreign tax credits, it is not practicable to determine the U.S. foreign income tax liability that would be payable if such earnings were not reinvested indefinitely.

Penalties and tax-related interest expense are reported as a component of income tax expense. For the years ended December 27, 2013 and December 28, 2012 the total amount of accrued income tax-related interest and penalties was $226 thousand and $212 thousand, respectively.

In accordance with ASC 740-10, the Company prescribes a more-likely-than-not threshold for financial statement recognition and measurement of a tax position taken or expected to be taken in a tax return. This interpretation also provides guidance on de-recognition of income tax assets and liabilities, classification of current and deferred income tax assets and liabilities, accounting for interest and penalties associated with tax positions, accounting for income taxes in interim periods and income tax disclosures.

The following table sets forth the detail and activity of the ASC 740-10 liability during the twelve months ended December 27, 2013 and December 28, 2012 (in thousands):


	Year Ended
	December 27, 2013	December 28, 2012
Beginning balance	$ 1,015	$ 170
Additions based on tax positions	-	845
Reduction for prior year tax deductions	(299)	-
Ending balance	$ 716	$ 1,015

As of December 27, 2013 and December 28, 2012, the ASC 740-10 liability of $0.7 million and $1.0 million, respectively, was classified as a current liability and included in the current portion of the accrued expenses and other liabilities in the accompanying consolidated balance sheets. The Company does not believe there will be any material changes in its unrecognized tax positions over the next twelve months. The reversal of ASC 740-10 tax liabilities as of December 27, 2013 and December 28, 2012 would have a favorable impact on the effective tax rate in future periods.