On December 22, 2017, the President of the United States signed into law the Tax Cuts and Jobs Act (“Tax Reform Act” or “the Act”). The legislation significantly changed U.S. tax law by, among other things, lowering corporate income tax rates, assessing a one-time transition tax on a deemed repatriation of non-previously taxed earnings of foreign subsidiaries, and implementing a territorial tax system.

While the Tax Reform Act provides for a territorial tax system, beginning in 2018, it includes two new U.S. tax base erosion provisions, the global intangible low-taxed income (“GILTI”) provisions and the base-erosion and anti-abuse tax (“BEAT”) provisions. The Act also provides for the foreign-derived intangible income (“FDII”) deduction for corporations that derive gross income from export activities

The GILTI provisions require the Company to include in its U.S. income tax return any foreign subsidiary earnings in excess of an allowable return on the foreign subsidiary’s tangible assets. For the years ended March 31, 2021, 2020, and 2019, the Company has not recorded material tax expense related to GILTI provisions. The Company has elected to account for GILTI tax in the period in which it is incurred, and therefore has not provided any deferred tax impacts of GILTI in its consolidated financial statements for the years ended March 31, 2021, 2020, and 2019.

The BEAT provisions in the Tax Reform Act eliminate the deduction of certain base-erosion payments made to related foreign corporations, and impose a minimum tax if greater than regular tax. The BEAT tax had no impact on the Company's consolidated financial statements for the years ended March 31, 2021, 2020, and 2019.

The FDII provisions of the Act provide an incentive to domestic corporations in the form of a lower tax rate on income derived from tangible and intangible products and services in foreign markets. This lower tax rate is accomplished via an additional tax deduction based on a percentage of qualifying sales. The FDII deduction provided the Company an additional tax benefit of $0, $1,029,000, and $945,000 in the years ended March 31, 2021, 2020, and 2019, respectively.

On December 22, 2017, the SEC staff issued Staff Accounting Bulletin No. 118 (“SAB 118”) to address the application of U.S. GAAP in situations when a registrant does not have the necessary information available, prepared, or analyzed (including computations) in reasonable detail to complete the accounting for certain income tax effects of the Tax Reform Act.

We applied the guidance in SAB 118 when accounting for the enactment-date effects of the Act in 2017 and throughout 2018. At December 31, 2017, we had not completed our accounting for all of the enactment-date income tax effects of the Act under ASC 740, Income Taxes, for the following aspects: remeasurement of deferred tax assets and liabilities and one-time transition tax. As of December 31, 2018, we completed our accounting for all of the enactment-date income tax effects of the Act, the impacts of which are summarized below.

The provision for income taxes differs from the amount computed by applying the statutory federal income tax rate to income from continuing operations before income tax expense. The sources and tax effects of the differences were as follows:


	Year Ended March 31,
	2021			2020			2019
Statutory federal income tax rate	21.00		%	21.00		%	21.00		%
Expected tax at statutory rate	$	2,116		$	16,203		$	11,108
Effect of Tax Reform Act (1)	—			—			(1,500)
State income taxes net of federal benefit	(450)			1,397			1,728
Foreign taxes at rates other than statutory federal rate	287			1,102			(145)
Net loss on sale of businesses (3)	—			—			4,041
Permanent items (6), (7)	178			266			(1,694)
Valuation allowance (2), (4)	84			(1,184)			13,190
Foreign tax credits (2)	—			—			(15,371)
Federal tax credits (5)	(700)			(1,903)			(1,376)
Other (8)	(545)			1,603			340
Actual tax provision expense	$	970		$	17,484		$	10,321

(2) For fiscal 2019, primarily represents foreign tax credits generated by the one-time transition tax calculation and valuation allowance as the Company believes their utilization is uncertain.

(4) For fiscal 2020, represents the reversal of a valuation allowance on certain foreign tax credits offset by increases in valuation allowances required in certain foreign jurisdiction.

(5) For fiscal 2021, Federal tax credits include research and development credits of $700,000. For fiscal 2020, Federal tax credits include research and development credits of $800,000 and minimum tax credits of $1,103,000. For fiscal 2019, Federal tax credits relate to research and development credits.


	Year Ended March 31,
	2021		2020		2019
Current income tax expense (benefit):
United States Federal	$	810	$	(2,491)	$	(1,663)
State taxes	618		626		394
Foreign	8,246		11,984		12,548
Deferred income tax expense (benefit):
United States	(5,996)		7,827		5,873
Foreign	(2,708)		(462)		(6,831)
	$	970	$	17,484	$	10,321

The Company applies the liability method of accounting for income taxes as required by ASC Topic 740, “Income Taxes.” The tax effects of temporary differences that give rise to significant portions of the deferred tax assets and deferred tax liabilities are as follows:


	March 31,
	2021		2020
Deferred tax assets:
Federal net operating loss carryforwards	$	16,038	$	18,091
State and foreign net operating loss carryforwards	7,404		7,142
Employee benefit plans	24,692		31,471
Insurance reserves	3,488		3,216
Accrued vacation and incentive costs	3,061		3,218
Federal tax credit carryforwards	13,238		11,922
ASC 842 Lease Liability	8,623		9,048
Equity compensation	2,782		1,974
Other	7,308		7,319
Valuation allowance	(15,103)		(15,036)
Deferred tax assets after valuation allowance	71,531		78,365
Deferred tax liabilities:
Property, plant, and equipment	(1,889)		(1,962)
ASC 842 Right-of-Use Asset	(8,446)		(8,938)
Intangible assets	(58,716)		(59,397)
Total deferred tax liabilities	(69,051)		(70,297)
Net deferred tax assets (liabilities)	$	2,480	$	8,068

The valuation allowance includes $2,896,000 and $2,696,000 related to foreign net operating losses at March 31, 2021 and 2020, respectively. The remaining valuation allowance primarily relates to foreign tax credits which the Company believes it will not utilize of $11,900,000 and $11,800,000 for the years ended March 31, 2021 and 2020, respectively. The Company’s foreign subsidiaries have net operating loss carryforwards of $10,552,000 that expire in periods ranging from five years to indefinite.

Federal net operating losses of $76,371,000 arose from the acquisition of Magnetek and have expiration dates ranging from 2022 through 2035 and are subject to certain limitations under U.S. tax law. The state net operating losses of $77,889,000 have expiration dates ranging from 2021 through 2041. The federal tax credits have expiration dates ranging from 2028 to 2041.


	March 31,
	2021		2020
Net non-current deferred tax assets	$	20,080	$	26,281
Net non-current deferred tax liabilities	(17,600)		(18,213)
Net deferred tax assets (liabilities)	$	2,480	$	8,068

Income from continuing operations before income tax expense includes foreign subsidiary income of $30,894,000, $37,577,000, and $14,362,000 for the years ended March 31, 2021, 2020, and 2019, respectively. As of March 31, 2021, the Company had approximately $69,000,000 of undistributed earnings of foreign subsidiaries. These earnings are considered to be

permanently invested in operations outside the U.S. with the exception of the current earnings from one foreign subsidiary. Any repatriation of these amounts would not be expected to result in a material increase to income tax expense due to the one-time transition tax and the new U.S. territorial tax system. Determination of the amount of unrecognized deferred U.S. income tax liability with respect to such earnings is not practicable.

During fiscal 2018, the Company adopted ASU No. 2016-09. There were shares of common stock issued through restricted stock units, the exercise of non-qualified stock options, or through the disqualifying disposition of incentive stock options in the years ended March 31, 2021 and 2020. The tax effect to the Company from these share transactions during fiscal 2021 and 2020 was a reduction to income tax expense of ($283,000) and ($169,000), respectively.


	2021		2020		2019
Beginning balance	$	132	$	936	$	592
Additions for tax positions of the current year	—		—		550
Reductions for prior year tax positions	—		(802)		(141)

Foreign currency translation	9		(2)		(65)
Lapses in statutes of limitation	—		—		—
Ending balance	$	141	$	132	$	936

The Company had $57,000, $46,000, and $38,000 accrued for the payment of interest and penalties at March 31, 2021, 2020, and 2019 respectively. The Company recognizes interest expense or penalties related to uncertain tax positions as a part of income tax expense in its consolidated statements of operations.

The Company’s major tax jurisdictions are the United States and Germany. With few exceptions, the Company is no longer subject to tax examinations by tax authorities in the United States for tax years prior to March 31, 2017 and in Germany for tax years prior to March 31, 2012. The Company has a current tax examination in Germany for fiscal years 2012 to 2014.

The Company anticipates that total unrecognized tax benefits will change due to the settlement of audits in certain foreign jurisdictions prior to March 31, 2022.