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Income Taxes
9 Months Ended
Mar. 27, 2016
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes
The variation between the Company's effective income tax rate and the U.S. statutory rate of 35% is due to the impact of the Company’s pre-tax income or loss relative to favorable tax rate impacts associated predominantly with the Company’s: (i) projected income for the full year derived from international locations with lower tax rates than the U.S. and (ii) projected tax credits generated. Tax credits and other deductions have the impact of increasing the tax rate above the statutory rate of 35% in periods in which the Company reports pre-tax losses as they provide a benefit that is recoverable in future periods.
U.S. GAAP requires a two-step approach to recognizing and measuring uncertain tax positions. The first step is to evaluate the tax position for recognition by determining if the weight of available evidence indicates that it is more likely than not that the position will be sustained on audit, including resolution of related appeals or litigation processes, if any. The second step is to measure the tax benefit as the largest amount that is cumulatively more than 50% likely to be realized upon ultimate settlement.
As of June 28, 2015, the Company's liability for unrecognized tax benefits was $17.8 million. During the nine months ended March 27, 2016, the Company recognized a $0.6 million increase to the liability for unrecognized tax benefits due to uncertainty regarding intercompany transactions recently challenged by the Italian tax authority. In addition, there was a $0.1 million decrease to the amount of unrecognized tax benefits following statute expirations. As a result, the total liability for unrecognized tax benefits as of March 27, 2016 was $18.3 million. If any portion of this $18.3 million is recognized, the Company will then include that portion in the computation of its effective tax rate. Although the ultimate timing of the resolution and/or closure of audits is highly uncertain, the Company believes it is reasonably possible that $4.3 million of gross unrecognized tax benefits will change in the next 12 months as a result of audit closures and statute requirements.
The Company files U.S. federal, U.S. state and foreign tax returns. For U.S. federal purposes, the Company is generally no longer subject to tax examinations for fiscal years prior to 2013. For U.S. state tax returns, the Company is generally no longer subject to tax examinations for fiscal years prior to 2012. For foreign purposes, the Company is generally no longer subject to tax examinations for tax periods 2005 and prior. Certain carryforward tax attributes generated in prior years remain subject to examination, adjustment and recapture. The Company is currently under audit by the Italian Revenue Agency for the fiscal year ended June 30, 2013.
During the three months ended September 27, 2015, the Company concluded that it is likely that $2.3 million of North Carolina income tax credits will expire unused. As a result, during that period, the Company recorded a $1.5 million valuation allowance against the related deferred tax asset, representing the $2.3 million expiring credits net of federal benefit. During the three months ended March 27, 2016, the Company concluded that it is likely an additional $0.6 million of North Carolina income tax credits will expire unused. The Company increased the valuation allowance against the related deferred tax asset by $0.4 million, representing the $0.6 million expiring tax credits net of federal benefit, resulting in an additional $0.4 million of income tax expense during the three months ended March 27, 2016.