11. Income Taxes


	Years Ended January 31,
	2014			2013			2012
	(in thousands)
Income (loss) before income taxes is attributable to the following jurisdictions:
Domestic	$	(4,323	)	$	(2,824	)	$	14,875
Foreign		10,349			16,348			19,455

Total	$	6,026		$	13,524		$	34,330

The components of income tax expense (benefit) were as follows:
Current:
Domestic	$	802		$	(2,306	)	$	4,090
Foreign		2,660			3,229			6,204

		3,462			923			10,294
Deferred:
Domestic		(3,039	)		(4,757	)		1,042
Foreign		835			307			(1,327	)

		(2,204	)		(4,450	)		(285	)

Income tax expense (benefit)	$	1,258		$	(3,527	)	$	10,009

The following is a reconciliation of expected to actual income tax expense:


	Years Ended January 31,
	2014			2013			2012
	(in thousands)
Federal income tax expense at 34% in 2014 and 2013 and 35% in 2012	$	2,049		$	4,598		$	12,016
Changes in tax rates		22			23			(7	)
Permanent differences		132			(741	)		347
Foreign effective tax rate differential		(1,884	)		(3,092	)		(2,574	)
Potential tax, penalties and interest resulting from uncertain tax positions		32			(5,059	)		529
Undistributed earnings of foreign affiliates		—			—			(435	)
Foreign withholding taxes		642			—			268
Other		265			744			(135	)

	$	1,258		$	(3,527	)	$	10,009

The components of the Company’s deferred taxes consisted of the following:


	As of January 31,
	2014			2013
	(in thousands)
Deferred tax assets:
Net operating losses	$	2,592		$	1,246
Tax credit carry forwards		3,470			3,449
Stock option book expense		2,689			2,605
Allowance for doubtful accounts		1,704			1,752
Allowance for inventory obsolescence		94			192
Accruals not yet deductible for tax purposes		620			692
Other		679			675

Gross deferred tax assets		11,848			10,611
Valuation allowance		—			—

Deferred tax assets		11,848			10,611
Deferred tax liabilities:
Fixed assets		(2,172	)		(1,841	)
Intangible assets		(435	)		(595	)
Foreign branch taxes		(1,140	)		(1,626	)
Other		—			(411	)

Deferred tax liabilities		(3,747	)		(4,473	)

Total deferred tax assets, net	$	8,101		$	6,138

In the fiscal year ended January 31, 2014, the cumulative book expense related to stock-based compensation awards exceeded the tax deduction related to these awards. Accordingly, the deferred tax asset related to these awards was reduced by the tax effect of approximately $5,000, which reduced paid-in capital. In the fiscal years ended January 31, 2013 and 2012, the tax deduction related to stock-based compensation awards exceeded the cumulative book expense related to these awards. The associated excess tax benefit amounting to approximately $420,000 and $778,000 was recognized as additional paid-in capital in the fiscal years ended January 31, 2013 and 2012, respectively.

At January 31, 2014, the Company had foreign withholding tax credit carry forwards of approximately $3,500,000 million, which amounts can be carried forward through at least 2024.

In July 2012, the Company reached a settlement with the Canadian Revenue Agency (“CRA”) and the Internal Revenue Service (“IRS”) regarding its request for competent authority assistance for matters arising from an audit of the Company’s Canadian income tax returns for the fiscal years ended January 31, 2004, 2005 and 2006. The issues involved related to intercompany repair charges, management fees and the deductibility of depreciation charges and whether those deductions should be taken in Canada or in the United States. Pursuant to the settlement agreement, adjustments have been, or will be, made to the Company’s Canadian and United States income tax returns for the fiscal years ended January 31, 2004 through January 31, 2012. These changes are estimated to result in a net reduction to consolidated income tax expense of approximately $141,000, which is reflected in the Company’s benefit from income taxes for the fiscal year ended January 31, 2013.

As a result of the settlement, in the fiscal year ended January 31, 2013, the Company recognized the benefit of certain tax positions amounting to approximately $3,300,000 and reversed previous estimates of potential penalties and interest amounting to approximately $1,900,000.

As of January 31, 2014 and 2013, the Company had unrecognized tax benefits amounting to approximately $408,000 and $376,000, respectively, attributable to uncertain tax positions. The Company recognizes interest and penalties related to income tax matters as a component of income tax expense. The unrecognized tax benefits attributable to uncertain tax positions include accrued interest and penalties of approximately $154,000 and $376,000 as of January 31, 2014 and January 31, 2013, respectively. Included in income tax expense for the fiscal year ended January 31, 2014 is a benefit related to a reduction in estimated potential penalties and interest. Included in income tax expense for the fiscal years ended January 31, 2013 and 2012 are expenses of $93,000 and $578,000, respectively, related to potential penalties and interest.

A reconciliation of the beginning and ending amounts of unrecognized tax benefits, excluding potential penalties and interest, is as follows:


	Years Ended January 31,
	2014		2013			2012
	(in thousands)
Unrecognized tax benefits as beginning of year	$	—	$	(3,300	)	$	(3,350	)
Increases (decreases) as a result of tax positions taken in prior years		254		—			50
Increases as a result of tax positions taken in current year		—		—			—
Settlements		—		3,300			—
Lapse of statute of limitations		—		—			—

Unrecognized tax benefits as of end of year	$	254	$	—		$	(3,300	)

The Company files U.S. federal income tax returns as well as separate returns for its foreign subsidiaries within their local jurisdictions. The Company’s U.S. federal tax returns are subject to examination by the IRS for fiscal years ended January 31, 2011 through 2014. The Company’s U.S. federal tax return for the year ended January 31, 2012 is currently under examination by the IRS. As of April 1, 2014, no adjustments have been proposed by the IRS. The Company’s tax returns may also be subject to examination by state and local revenue authorities for fiscal years ended January 31, 2009 through 2014.The Company’s Canadian income tax returns are subject to examination by the Canadian tax authorities for fiscal years ended January 31, 2010 through 2014. The Company’s tax returns in other foreign jurisdictions are generally subject to examination for the fiscal years ended January 31, 2009 through January 31, 2014.