Taxes

Income Taxes. Deferred income taxes reflect the net tax effects of temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for income tax purposes. Significant components of the consolidated deferred tax assets and liabilities were (in thousands):



Fiscal Year	2017			2016
Deferred income tax assets (liabilities):
Bad debt allowance	$	2,920		$	3,936
Returns allowance	3,662			5,464
Inventory	13,409			15,243
Warranty liabilities	2,656			3,244
Compensation	19,005			19,286
Accrued liabilities	9,881			7,276
Deferred rent	12,403			17,518
Unrealized exchange gains (losses)	5,553			(6,498		)
State income tax and interest on tax contingencies	1,410			2,808
Fixed assets	(13,442		)	(20,872		)
Trade names and customer lists	(2,607		)	(26,166		)
Goodwill	19,982			(16,758		)
Other intangibles	(5,985		)	(11,414		)
Undistributed earnings of certain foreign subsidiaries	(1,018		)	(53,761		)
Foreign accruals	8,501			8,503
Loss carryforwards	27,868			20,898
Tax credit carryforwards	—			17,363
Valuation allowance	(78,314		)	(19,415		)
Other	132			529
Net deferred income tax assets (liabilities)	$	26,016		$	(32,816	)
Total deferred income tax assets	$	27,112		$	23,061
Total deferred income tax liabilities	(1,096		)	(55,877		)
Net deferred income tax assets (liabilities)	$	26,016		$	(32,816	)

Operating Loss Carryforwards. The balance sheet includes $27.9 million of deferred tax assets for net operating losses of foreign subsidiaries. Valuation allowances have been recorded to reflect the estimated amount of deferred tax assets that may not be realized on these losses. The amounts and the fiscal year of expiration of the loss carryforwards are (in thousands):



Expires 2018 through 2022	$	37,291
Expires 2023 through 2027	26,082
Expires 2028 through 2032	5,979
Expires 2033 through 2037	32,439
Indefinite	19,176
Total loss carryforwards	$	120,967

The following table identifies income (loss) before income taxes for the Company's U.S. and non-U.S. based operations for the fiscal years indicated (in thousands):



Fiscal Year	2017			2016			2015
U.S	$	(517,227	)	$	(72,249	)	$	24,864
Non-U.S	63,473			186,557			286,795
Total	$	(453,754	)	$	114,308		$	311,659

The Company's provision for income taxes consisted of the following for the fiscal years indicated (in thousands):



Fiscal Year	2017			2016			2015
Current provision:
U.S. federal	$	30,817		$	2,111		$	10,666
Non-U.S	40,423			53,880			72,336
State and local	(2,055		)	(1,482		)	1,180
Total current	69,185			54,509			84,182
Deferred provision (benefit):
U.S. federal	(45,990		)	(20,216		)	1,798
Non-U.S	(3,770		)	(5,584		)	(4,511		)
State and local	380			(4		)	288
Total deferred	(49,380		)	(25,804		)	(2,425		)
Provision for income taxes	$	19,805		$	28,705		$	81,757

The expected cash payments for current U.S. income tax expense for fiscal years 2017, 2016 and 2015 were reduced by approximately $1.6 million, $3.3 million and $2.4 million, respectively, as a result of tax deductions related to the exercise of non-qualified stock options and stock appreciation rights and the vesting of restricted stock and restricted stock units. The expected cash payments for current foreign tax expense for fiscal years 2017, 2016 and 2015 were reduced by $0.1 million, $0.2 million and $0.3 million, respectively, as a result of tax deductions related to the exercise of stock options and the vesting of restricted stock granted to foreign employees. The income tax benefits resulting from these stock-based compensation plans have been recorded to additional paid-in capital in the Company's consolidated balance sheets. Total deferred income tax expense of $49.4 million, $25.8 million and $2.4 million for fiscal years 2017, 2016 and 2015, respectively, are included in deferred income taxes on the Company's consolidated statements of cash flows.

A reconciliation of the U.S. federal statutory income tax rate of 35.0% to the Company's effective tax rate is as follows:



Fiscal Year	2017		2016		2015
Tax at statutory rate	35.0	%	35.0	%	35.0	%
Non-deductible expenses	(0.6	)	5.3		0.7
State, net of federal tax benefit	1.0		0.6		0.5
Foreign rate differential	3.7		(30.9	)	(15.6	)
U.S. tax on foreign income	(1.7	)	5.0		4.3
Valuation allowances	(12.5	)	8.1		1.4
Repatriation tax - net impact	(7.4	)	—		—
Non-deductible goodwill impairment	(15.2	)	—		—
Tax Reform rate reduction impact on deferred tax assets	(6.2	)	—		—
Other	(0.5	)	2.0		(0.1	)
Provision for income taxes	(4.4	)%	25.1	%	26.2	%

On December 22, 2017, the U.S. government enacted comprehensive tax legislation that significantly revised the Internal Revenue Code of 1986, including a corporate income tax rate reduction from 35% to 21%, under the Tax Cuts and Jobs Act (the “Tax Act”). The newly enacted federal income tax law contains significant changes in the taxation of foreign income earned by U.S. shareholders, specifically adding new rules related to low-taxed foreign earnings and allowing an exemption on foreign dividends paid after 2017. In anticipation of the tax exemption on foreign dividends, the law imposes a one-time repatriation tax on historical earnings generated offshore that have not been previously taxed in the U.S. Foreign earnings held in cash or liquid assets are taxed at 15.5%, and the remaining earnings are taxed at 8%. The Company accrued $86.4 million for the repatriation tax and released $52.8 million in deferred tax liabilities for foreign earnings not indefinitely reinvested, resulting in a net charge of $33.6 million. After applying foreign tax credit carry forwards and the current year net operating loss, the actual cash repatriation tax liability is expected to be $15.7 million, payable in installments over eight years.

Accounting for the income tax effects of the Tax Act requires significant judgments and estimates in the interpretation and calculations of the provisions of the Tax Act. Due to the timing of the enactment and the complexity involved in applying the provisions of the Tax Act, the Company has made reasonable estimates of the effects and recorded provisional amounts in its financial statements for fiscal year 2017 as permitted under SAB 118. As the Company collects and prepares necessary data, and interprets any additional guidance issued by the U.S. Treasury Department or the Internal Revenue Service, the Company may make adjustments to the provisional amounts. In addition, the Company's valuation allowance analysis is affected by various aspects of the Tax Act, including the new limitation on the deductibility of interest expense and the impact of the GILTI. Those adjustments may materially impact the provision for income taxes and the effective tax rate in the period in which the adjustments are made. The accounting for the tax effects of the enactment of the Tax Act will be completed in fiscal year 2018.

The Company recognized expense of $28.2 million on the reduction in U.S. deferred tax assets as a result of the corporate income tax reduction from 35% to 21%. The Company also accrued valuation allowances of $44.7 million on net U.S deferred tax assets and $11.8 million on net foreign deferred tax assets. The effective tax rate was also impacted by non-deductible intangible asset impairment charges recognized during fiscal year 2017.

The Company will not indefinitely reinvest $650.3 million of earnings of foreign subsidiaries. Since under the Tax Act there will be no additional federal income tax when these amounts are repatriated, and the foreign jurisdiction does not impose a withholding tax on dividends, the Company has only accrued state income taxes on these earnings. Deferred U.S. federal income taxes and foreign withholding taxes are not recorded on the remaining $378.0 million of undistributed earnings of foreign subsidiaries where management plans to continue reinvesting these earnings outside the U.S. Determining tax amounts that would be payable if these earnings were distributed to the U.S. parent company is not practicable.

The total amount of unrecognized tax benefits, excluding interest and penalties that would favorably impact the effective tax rate in future periods if recognized, was $33.0 million, $20.6 million and $20.0 million for fiscal years 2017, 2016 and 2015, respectively. The U.S. Internal Revenue Service has completed examinations of the Company's federal income tax returns through 2013. Fiscal years 2014-2017 remain open for federal income tax examination. The Company is also subject to examinations in various state and foreign jurisdictions for its 2011-2016 tax years, none of which the Company believes are significant, individually or in the aggregate. Tax audit outcomes and timing of tax audit settlements are subject to significant uncertainty.

The Company has classified uncertain tax positions as long-term income taxes payable unless such amounts are expected to be paid within twelve months from December 30, 2017. As of December 30, 2017, the Company had recorded $5.4 million of unrecognized tax benefits, excluding interest and penalties, for positions that could be settled within the next twelve months. Consistent with its past practice, the Company recognizes interest and/or penalties related to income tax overpayments and income tax underpayments in income tax expense and income taxes receivable/payable, respectively. The total amount of accrued income tax-related interest in the Company's consolidated balance sheets was $2.8 million and $2.3 million at December 30, 2017 and December 31, 2016, respectively. The total amount of accrued income tax-related penalties in the Company's consolidated balance sheets was $1.3 million and $1.4 million at December 30, 2017 and December 31, 2016, respectively. The Company accrued income tax-related interest expense of $0.5 million, $0.1 million and $0.3 million in fiscal years 2017, 2016 and 2015, respectively.

The following is a tabular reconciliation of the total amounts of unrecognized tax benefits for the fiscal years indicated (in thousands):



Fiscal Year	2017			2016			2015
Balance at beginning of year	$	23,399		$	23,022		$	20,086
Gross increases tax positions in prior years	2,104			918			1,800
Gross decreases tax positions in prior years	(845		)	(183		)	(9,282		)
Gross increases—tax positions in current year	13,444			974			11,909
Settlements	(81		)	(181		)	(583		)
Lapse in statute of limitations	(2,706		)	(1,106		)	(758		)
Change due to currency revaluation	40			(45		)	(150		)
Balance at end of year	$	35,355		$	23,399		$	23,022