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Income Taxes
 12 Months Ended
Jun. 27, 2021
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The following were the components of loss before income taxes:
 Fiscal Years Ended
(in millions of U.S. Dollars)June 27, 2021June 28, 2020June 30, 2019
Domestic($348.7)($210.3)($92.2)
Foreign8.5 4.7 (30.7)
Loss before income taxes($340.2)($205.6)($122.9)
The following were the components of income tax expense (benefit):
 Fiscal Years Ended
(in millions of U.S. Dollars)June 27, 2021June 28, 2020June 30, 2019
Current:
Federal$0.1 ($7.3)$1.4 
Foreign0.1 0.2 0.5 
State0.2 0.1 0.3 
Total current0.4 (7.0)2.2 
Deferred:
Federal0.7 1.8 (1.9)
Foreign— (2.8)(4.5)
State— — (0.2)
Total deferred0.7 (1.0)(6.6)
Income tax expense (benefit)$1.1 ($8.0)($4.4)
Actual income tax expense (benefit) differed from the amount computed by applying each period's U.S. federal statutory tax rate to pre-tax earnings as a result of the following:
 Fiscal Years Ended
(in millions of U.S. Dollars)June 27, 2021% of LossJune 28, 2020% of LossJune 30, 2019% of Loss
Federal income tax provision at statutory rate($71.4)21 %($43.2)21 %($25.8)21 %
(Decrease) increase in income tax expense resulting from:
State tax provision, net of federal benefit(1.9)1 %(1.9)1 %(2.0)2 %
Tax exempt interest(0.1)— %(0.5)— %(0.4)— %
(Decrease) increase in tax reserve— — %(0.3)— %0.5 — %
Research and development credits(4.3)1 %(3.3)2 %(2.8)2 %
Foreign tax credit(0.4)— %(0.3)— %(0.4)— %
Increase (decrease) in valuation allowance75.0 (22)%50.3 (25)%4.3 (4)%
Partial extinguishment of convertible notes— — %(6.0)3 %— — %
Stock-based compensation(2.8)1 %2.1 (1)%0.7 (1)%
Statutory rate differences1.1 — %1.2 (1)%6.0 (5)%
Foreign earnings taxed in U.S.2.7 (1)%0.3 — %0.4 — %
Other foreign adjustments(0.1)— %0.3 — %(0.1)— %
Net operating loss carryback— — %(7.2)4 %— — %
Provision to return adjustments(0.2)— %(1.3)1 %11.8 (10)%
Tax on distributable foreign earnings— — %— — %— — %
Impact of rate changes2.7 (1)%0.8 — %2.7 (2)%
Expiration of state credits0.7 — %0.9 — %1.2 (1)%
Other0.1 — %0.1 — %(0.5)— %
Income tax expense (benefit)$1.1 — %($8.0)4 %($4.4)4 %
The tax effects of temporary differences that give rise to significant portions of the deferred tax assets and deferred tax liabilities were as follows:
(in millions of U.S. Dollars)June 27, 2021June 28, 2020
Deferred tax assets:
Compensation$10.4 $4.4 
Inventories13.6 7.9 
Sales return reserve and allowance for bad debts2.3 2.6 
Federal and state net operating loss carryforwards360.6 180.1 
Federal credits42.1 30.3 
State credits1.2 1.9 
48C investment tax credits36.6 37.5 
Investments0.3 — 
Stock-based compensation6.1 8.3 
Deferred revenue26.3 23.1 
Lease liabilities6.2 6.5 
Other4.5 5.0 
Total gross deferred assets510.2 307.6 
Less valuation allowance(414.4)(208.5)
Deferred tax assets, net95.8 99.1 
Deferred tax liabilities:
Property and equipment(36.9)(27.8)
Intangible assets(16.6)(19.2)
Investments(1.1)(1.6)
Prepaid taxes and other(0.7)(0.7)
Foreign earnings recapture— (2.0)
Taxes on unremitted foreign earnings(1.5)— 
Lease assets(6.1)(6.3)
Convertible notes(34.4)(42.1)
Total gross deferred liability(97.3)(99.7)
Deferred tax liability, net($1.5)($0.6)
The components giving rise to the net deferred tax assets (liabilities) have been included in the consolidated balance sheets as follows:
 Balance at June 27, 2021
(in millions of U.S. Dollars)AssetsLiabilities
U.S. federal income taxes$— ($2.5)
Foreign income taxes1.0 — 
Total$1.0 ($2.5)
 Balance at June 28, 2020
(in millions of U.S. Dollars)AssetsLiabilities
U.S. federal income taxes$— ($1.8)
Foreign income taxes1.2 — 
Total$1.2 ($1.8)
The Company weighs all available evidence, both positive and negative, to estimate if sufficient future taxable income will be generated to utilize the existing deferred tax assets by jurisdiction. The Company has concluded that it is necessary to recognize a full valuation allowance against its U.S. and Luxembourg deferred tax assets as of June 27, 2021. As of June 28, 2020, the U.S. valuation allowance was $205.2 million. For the fiscal year ended June 27, 2021, the Company increased the U.S. valuation allowance by $87.4 million primarily due to the Company's current year domestic loss and tax credits generated. As of June 28, 2020, the Luxembourg valuation allowance was $3.3 million. For the fiscal year ended June 27, 2021, the Company increased this valuation allowance by $118.5 million due to the current year loss in Luxembourg driven primarily by the LED Business Divestiture.
As a result of the LED Business Divestiture and the liquidation of the Company’s common stock ownership interest in ENNOSTAR, the Company began reviewing its legal entity structure, including its Luxembourg holding company, during the fourth quarter of fiscal 2021. As of June 27, 2021, the Company is still performing the due diligence necessary to understand its ability and desire to restructure its Luxembourg holding company. If the Company determines it is willing and able to execute a restructuring of its Luxembourg holding company, it is reasonably possible the action could generate taxable income of the right character to utilize all or a portion of the Company’s existing $121.8 million of deferred tax assets in Luxembourg. As a result, the Company believes it is reasonably possible within the next twelve months, and potentially as early as the first quarter of fiscal 2022, that objective positive evidence may become available to allow the Company to conclude all or a portion of the $121.8 million of Luxembourg deferred tax assets are realizable. This determination would result in the release of all or a portion of the Luxembourg valuation allowance. The release of the Luxembourg valuation allowance could result in the recognition of $121.8 million of net operating loss deferred tax assets and a decrease to income tax expense in the period the release is recorded.
As of June 27, 2021, the Company had approximately $491.8 million of foreign net operating loss carryovers, of which $488.5 million are offset by a valuation allowance. Of the Company's foreign net operating loss carryovers, $7.8 million have no carry forward limitation and the remaining $484.0 million will begin to expire in fiscal 2035. As of June 27, 2021, the Company had approximately $1.1 billion of federal net operating loss carryovers and $251.0 million of state net operating loss carryovers which are fully offset by a valuation allowance. Additionally, the Company had $78.7 million of federal and $1.6 million of state income tax credit carryforwards which are fully offset by a valuation allowance. The federal and state net operating loss carryovers will begin to expire in fiscal 2038 and fiscal 2022, respectively. The federal and state income tax credit carryforwards will begin to expire in fiscal 2031 and fiscal 2022, respectively.
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, 2020, the Company’s liability for unrecognized tax benefits was $7.4 million. During the fiscal year ended June 27, 2021, the Company had no material changes to its unrecognized tax benefits. As a result, the total liability for unrecognized tax benefits as of June 27, 2021 was $7.4 million. If any portion of this $7.4 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 $0.6 million of gross unrecognized tax benefits will change in the next 12 months as a result of statute requirements or settlement with tax authorities.
The following is a tabular reconciliation of the Company’s change in uncertain tax positions:
Fiscal Years Ended
(in millions of U.S. Dollars)June 27, 2021June 28, 2020June 30, 2019
Balance at beginning of period$7.4 $8.2 $8.6 
Decrease related to current year change in law— — — 
Increases related to prior year tax positions— — 0.5 
Decreases related to prior year tax positions— — — 
Settlements with tax authorities— (0.1)— 
Expiration of statute of limitations for assessment of taxes— (0.7)(0.9)
Balance at end of period$7.4 $7.4 $8.2 
The Company's policy is to include interest and penalties related to unrecognized tax benefits within the income tax expense (benefit) line item in the consolidated statements of operations. Interest and penalties relating to unrecognized tax benefits recognized in the consolidated statements of operations totaled less than $0.1 million for the fiscal years ended June 27, 2021, June 28, 2020, and June 30, 2019. The Company accrued less than $0.1 million for interest and penalties relating to unrecognized tax benefits in the consolidated balance sheets as of June 27, 2021 and June 28, 2020.
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 2017. For U.S. state tax returns, the Company is generally no longer subject to tax examinations for fiscal years prior to 2017. For foreign purposes, the Company is generally no longer subject to examination for tax periods prior to 2011. Certain carryforward tax attributes generated in prior years remain subject to examination, adjustment and recapture.
The Company provides for income taxes on the earnings of foreign subsidiaries unless the subsidiaries’ earnings are considered indefinitely reinvested outside the United States. As of June 27, 2021, the Company has approximately $189.7 million of undistributed earnings for certain non-U.S. subsidiaries. The Company has determined that $171.4 million of the $189.7 million of undistributed foreign earnings are expected to be repatriated in the foreseeable future. The Company expects to incur $1.4 million of foreign income taxes upon repatriation of the $171.4 million foreign earnings. As of June 27, 2021, the Company has not provided income taxes on the remaining undistributed foreign earnings of $18.3 million as the Company continues to maintain its intention to reinvest these earnings in foreign operations indefinitely. If, at a later date, these earnings were repatriated to the United States, the Company would be required to pay approximately $0.3 million in taxes on these amounts.