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INCOME TAXES
3 Months Ended
Jan. 31, 2020
INCOME TAXES  
INCOME TAXES

13.  INCOME TAXES

In December 2017, the Tax Cuts and Jobs Act (the “Tax Reform Act”) was enacted. The Tax Reform Act lowered the U.S. corporate tax rate from 35% to 21%, implemented a territorial tax system from a worldwide system, imposed a tax on deemed repatriation of earnings of foreign subsidiaries and added provisions related to Global Intangible Low Taxed Income (“GILTI”) and Foreign-Derived Intangible Income (”FDII”), among other provisions.

The Tax Reform Act created a new requirement that GILTI income earned by Controlled Foreign Corporations (“CFCs”) must be included in the gross income of the CFC’s U.S. shareholder. We have elected the period cost method to account for GILTI tax. The Tax Reform Act also created the FDII for U.S. companies that derive income from the export of tangible and intangible property and services.  We have included an estimate for the GILTI and FDII in our annualized effective tax rate used to determine tax expense (benefit) for the three months ended January 31, 2020.

We recorded an income tax benefit during the first three months of fiscal 2020 of $597,000 compared to income tax expense of $2.5 million for the same period in fiscal 2019. Our effective tax rate for the first three months of fiscal 2020 was 40% in comparison to 27% for the same period in fiscal 2019. The increase in effective tax rate was primarily due to a shift in geographic mix of income and loss among tax jurisdictions. The shift in geographic mix of income and loss during the quarter created an unfavorable impact of certain U.S. tax reform provisions in the current fiscal year related to deductions for FDII and  minimal tax provisions for GILTI.

Our unrecognized tax benefits were $228,000 as of January 31, 2020 and $225,000 as of October 31, 2019, and in each case included accrued interest.

We recognize accrued interest and penalties related to unrecognized tax benefits as components of income tax expense. As of January 31, 2020, the gross amount of interest accrued, reported in Accrued expenses, was approximately $35,000, which did not include the federal tax benefit of interest deductions.

We file U.S. federal and state income tax returns, as well as tax returns in several foreign jurisdictions. The statutes of limitations with respect to unrecognized tax benefits will expire between July 2020 and August 2023.