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Income Taxes
 12 Months Ended
Jun. 30, 2024
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 30, 2024June 25, 2023June 26, 2022
Domestic($572.2)($262.6)($244.3)
Foreign(0.3)2.8 2.4 
Loss before income taxes($572.5)($259.8)($241.9)
The following were the components of income tax expense:
 Fiscal Years Ended
(in millions of U.S. Dollars)June 30, 2024June 25, 2023June 26, 2022
Current:
Federal$— $0.3 $0.3 
Foreign0.9 0.5 7.9 
State0.2 0.1 0.1 
Total current1.1 0.9 8.3 
Deferred:
Federal— — — 
Foreign— (0.2)(0.1)
State— — — 
Total deferred— (0.2)(0.1)
Income tax expense$1.1 $0.7 $8.2 
Actual income tax expense differed from the amount computed by applying each period's United States federal statutory tax rate to pre-tax earnings as a result of the following:
 Fiscal Years Ended
(in millions of U.S. Dollars)June 30, 2024% of LossJune 25, 2023% of LossJune 26, 2022% of Loss
Federal income tax provision at statutory rate($120.2)21 %($54.6)21 %($50.8)21 %
(Decrease) increase in income tax expense resulting from:
State tax provision, net of federal benefit(5.0)1 %(0.7)— %(2.2)1 %
Tax exempt interest(0.4)— %(0.5)— %(0.2)— %
(Decrease) increase in tax reserve(2.0)— %(0.4)— %(0.2)— %
Research and development credits(9.7)2 %(8.7)3 %(4.6)2 %
Foreign tax credit— — %— — %(0.3)— %
Increase (decrease) in valuation allowance127.0 (22)%62.0 (24)%(63.1)26 %
Extinguishment of convertible notes— — %— — %(4.5)2 %
Stock-based compensation8.8 (2)%3.0 (1)%(2.9)1 %
Statutory rate differences— — %0.1 — %— — %
Foreign earnings taxed in U.S.0.4 — %(0.4)— %6.8 (3)%
Provision to return adjustments(0.4)— %0.1 — %0.3 — %
Impact of rate changes0.4 — %— — %0.5 — %
Expiration of attributes2.0 — %0.2 — %0.1 — %
Corporate restructuring adjustment— — %— — %129.1 (53)%
Other0.2 — %0.6 — %0.2 — %
Income tax expense$1.1 — %$0.7 — %$8.2 (3)%
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 30, 2024June 25, 2023
Deferred tax assets:
Compensation$5.4 $7.7 
Inventories45.4 39.3 
Sales return reserve and allowance for bad debts11.2 7.0 
Federal and state net operating loss carryforwards506.8 366.1 
Federal income tax credits69.7 59.0 
State income tax credits0.7 1.0 
48C investment tax credits35.7 35.7 
Investments2.3 5.2 
Stock-based compensation10.7 10.0 
Deferred revenue35.0 9.0 
Lease liabilities28.7 29.5 
Capitalized research and development101.6 57.1 
Convertible notes62.6 73.7 
Nondeductible interest carryforward27.7 2.4 
Other3.0 4.5 
Total gross deferred assets946.5 707.2 
Less valuation allowance(734.1)(543.9)
Deferred tax assets, net212.4 163.3 
Deferred tax liabilities:
Property and equipment(123.8)(107.1)
Intangible assets(58.6)(22.7)
Other long-term investments(4.0)— 
Prepaid taxes(0.5)(0.5)
Foreign earnings recapture(4.2)(4.3)
Taxes on unremitted foreign earnings(6.9)(6.5)
Lease assets(23.8)(24.9)
Other(0.3)— 
Total gross deferred liability(222.1)(166.0)
Deferred tax liability, net($9.7)($2.7)
The components giving rise to the net deferred tax assets (liabilities) have been included in the consolidated balance sheets as follows:
 Balance at June 30, 2024
(in millions of U.S. Dollars)AssetsLiabilities
U.S. federal income taxes$— ($10.8)
Foreign income taxes1.1 — 
Total$1.1 ($10.8)
 Balance at June 25, 2023
(in millions of U.S. Dollars)AssetsLiabilities
U.S. federal income taxes$— ($3.9)
Foreign income taxes1.2 — 
Total$1.2 ($3.9)
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 United States deferred tax assets as of June 30, 2024. As of June 25, 2023, the United States valuation allowance was $543.9 million. For the fiscal year ended June 30, 2024, the Company increased the United States valuation allowance by $190.1 million due to increases in deferred tax assets related to the current year domestic loss and domestic capitalized research and development. The Company has immaterial valuation allowances against deferred tax assets in international jurisdictions which increased $0.1 million during the fiscal year ended June 30, 2024.
As of June 30, 2024, the Company had approximately $2.3 billion of federal net operating loss carryovers which are fully offset by liabilities for unrecognized tax benefits and valuation allowance. Of the Company's federal net operating loss carryovers, $145.0 million begin to expire in fiscal 2038 while the remaining carryovers have no carry forward limitation. The Company has $495.1 million of state net operating loss carryovers which are fully offset due to a valuation allowance. The Company's state net operating loss carryovers begin to expire in fiscal 2025. Additionally, the Company had $110.0 million of federal credit carryforwards, which are fully offset by liabilities for unrecognized tax benefits and a valuation allowance, and $0.7 million of state income tax credit carryforwards, which are fully offset by a valuation allowance. The federal and state income tax credit carryforwards will begin to expire in fiscal 2031 and fiscal 2026, respectively. As of June 30, 2024, the Company had approximately $1.9 million of foreign net operating loss carryovers, of which $0.3 million are offset by a valuation allowance. The Company's foreign net operating loss carryovers have no carry forward limitation.
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 25, 2023, the Company’s liability for unrecognized tax benefits was $9.8 million. During the fiscal year ended June 30, 2024, the liability for unrecognized tax benefits decreased $0.4 million, primarily due to a decrease of $2.0 million for expiration of statute of limitations, offset by an increase of $1.7 million due to generated research and development credits. As a result, the total liability for unrecognized tax benefits as of June 30, 2024 was $9.4 million. If any portion of this $9.4 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 $0.4 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 30, 2024June 25, 2023June 26, 2022
Balance at beginning of period$9.8 $7.2 $7.4 
Increases related to prior year tax positions— 1.7 — 
Decreases related to prior year tax positions(0.1)— — 
Settlements with tax authorities— (0.2)— 
Expiration of statute of limitations for assessment of taxes(2.0)(0.1)(0.2)
Increases related to current year positions1.7 1.2 — 
Balance at end of period$9.4 $9.8 $7.2 
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 30, 2024, June 25, 2023, and June 26, 2022. 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 30, 2024 and June 25, 2023.
The Company files United States federal, United States state and foreign tax returns. For United States federal purposes, the Company is generally no longer subject to tax examinations for fiscal years prior to 2018. For United States state tax returns, the Company is generally no longer subject to tax examinations for fiscal years prior to 2019. For foreign purposes, the Company is generally no longer subject to examination for tax periods prior to 2014. 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 30, 2024, the Company has approximately $206.6 million of undistributed earnings for certain non-United States subsidiaries. The Company has determined that $189.7 million of the $206.6 million of undistributed foreign earnings are expected to be repatriated in the foreseeable future. The Company expects to incur $6.9 million of foreign income taxes upon repatriation of the $189.7 million foreign earnings. As of June 30, 2024, the Company has not provided income taxes on the remaining undistributed foreign earnings of $16.9 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 $0.2 million in taxes on these amounts.