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Income Taxes
12 Months Ended
Mar. 31, 2019
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The Company is incorporated in Switzerland but operates in various countries with differing tax laws and rates. Further, a portion of the Company's income (loss) before taxes and the provision for (benefit from) income taxes is generated outside of Switzerland.
Income from continuing operations before income taxes for fiscal years 2019, 2018 and 2017 is summarized as follows (in thousands):
 
 
Years Ended March 31,
 
 
2019
 
2018
 
2017
Swiss
 
$
212,986

 
$
177,935

 
$
161,544

Non-Swiss
 
58,147

 
54,330

 
53,445

Income before taxes
 
$
271,133

 
$
232,265

 
$
214,989


The provision for (benefit from) income taxes is summarized as follows (in thousands):
 
 
Years Ended March 31,
 
 
2019
 
2018
 
2017
Current:
 
 
 
 
 
 
Swiss
 
$
1,364

 
$
3,526

 
$
1,934

Non-Swiss
 
24,334

 
13,142

 
9,774

Deferred:
 
 
 
 
 
 
Non-Swiss
 
(12,138
)
 
7,055

 
(2,595
)
Provision for income taxes
 
$
13,560

 
$
23,723

 
$
9,113


The difference between the provision for income taxes and the expected tax provision at the statutory income tax rate of 8.5% is reconciled below (in thousands):
 
 
Years Ended March 31,
 
 
2019
 
2018
 
2017
Expected tax provision at statutory income tax rates
 
$
23,046

 
$
19,743

 
$
18,274

Income taxes at different rates
 
(10,113
)
 
(9,611
)
 
(5,247
)
Research and development tax credits
 
(5,432
)
 
(4,124
)
 
(2,309
)
Executive compensation
 
3,344

 
1,835

 
654

Stock-based compensation
 
(7,288
)
 
(9,376
)
 
1,794

Deferred tax effects from Tax Act
 

 
22,325

 

Valuation allowance
 
1,891

 
533

 
1,024

Restructuring charges / (credits)
 
961

 
(10
)
 
2

Tax reserves (releases), net
 
8,269

 
3,627

 
(5,570
)
Other, net
 
(1,118
)
 
(1,219
)
 
491

Provision for income taxes
 
$
13,560

 
$
23,723

 
$
9,113


Deferred income tax assets and liabilities consist of the following (in thousands):
 
 
March 31,
 
 
2019
 
2018
Deferred tax assets:
 
 

 
 

Net operating loss carryforwards
 
$
16,323

 
$
15,476

Tax credit carryforwards
 
52,263

 
45,421

Accruals
 
52,304

 
42,765

Depreciation and amortization
 
5,716

 
1,505

Share-based compensation
 
8,703

 
7,479

Gross deferred tax assets
 
135,309

 
112,646

Valuation allowance
 
(28,375
)
 
(25,148
)
Gross deferred tax assets after valuation allowance
 
106,934

 
87,498

Deferred tax liabilities:
 
 

 
 

Acquired intangible assets and other
 
(18,176
)
 
(4,827
)
Gross deferred tax liabilities
 
(18,176
)
 
(4,827
)
Deferred tax assets, net
 
$
88,758

 
$
82,671

The Tax Act enacted in the United States in fiscal year 2018 permanently reduced the corporate income tax rate from 35% to 21% effective for tax years including or commencing on January 1, 2018. It also repealed corporate alternative minimum tax, limited various business deductions such as executive compensation under IRC 162(m) and modified the maximum deduction of net operating loss with no carryback but indefinite carryforward provision among other things. The Company recorded a provisional income tax charge of $21.7 million, net of valuation allowance against tax credits, in fiscal year 2018 to remeasure the deferred tax effects at 21%.

The Company completed its review, in the third quarter of fiscal year 2019, of previously recorded provisional income tax amounts related to net deferred tax assets impacted by the Tax Act and concluded that additional information, interpretation and guidance that became available during the twelve-month measurement period did not alter the Company’s application of tax law in remeasuring gross deferred tax assets and related valuation allowance. There were no adjustments deemed necessary in fiscal year 2019.
Management regularly assesses the ability to realize deferred tax assets recorded in the Company's entities based upon the weight of available evidence, including such factors as recent earnings history and expected future taxable income. In the event that the Company changes its determination as to the amount of deferred tax assets
that can be realized, the Company will adjust its valuation allowance with a corresponding impact to the provision for income taxes in the period in which such determination is made.
The Company had a valuation allowance of $28.4 million at March 31, 2019, compared to $25.1 million at March 31, 2018. The federal valuation allowance against tax credits was reduced from $2.3 million as of March 31, 2018 to $1.9 million as of March 31, 2019 due to a release of $0.4 million. The Company had a valuation allowance of $25.7 million as of March 31, 2019 against deferred tax assets in the state of California, an increase from $22.1 million as of March 31, 2018. The increase primarily relates to $2.3 million and $1.3 million from activities related to deferred tax assets and the acquisition of Blue Microphones, respectively. The remaining valuation allowance primarily represents $0.8 million for various tax credit carryforwards. The Company determined that it is more likely than not that the Company would not generate sufficient taxable income in the future to utilize such deferred tax assets.
As of March 31, 2019, the Company had foreign net operating loss and tax credit carryforwards for income tax purposes of $252.6 million and $58.1 million. Unused net operating loss carryforwards will expire at various dates in fiscal years 2020 to 2039. Certain net operating loss carryforwards in the United States relate to acquisitions and, as a result, are limited in the amount that can be utilized in any one year. The tax credit carryforwards will begin to expire in fiscal year 2020.
Swiss income taxes and non-Swiss withholding taxes associated with the repatriation of earnings or for other temporary differences related to investments in non-Swiss subsidiaries have not been provided for, as the Company intends to reinvest the earnings of such subsidiaries indefinitely or the Company has concluded that no additional tax liability would arise on the distribution of such earnings. If these earnings were distributed to Switzerland in the form of dividends or otherwise, or if the shares of the relevant non-Swiss subsidiaries were sold or otherwise transferred, the Company may be subject to additional Swiss income taxes and non-Swiss withholding taxes. As of March 31, 2019, the cumulative amount of unremitted earnings of non-Swiss subsidiaries for which no income taxes have been provided is approximately $100.3 million. The amount of unrecognized deferred income tax liability related to these earnings is estimated to be approximately $0.8 million.
The Company follows a two-step approach in 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 more than 50% likely of being realized upon ultimate settlement.
As of March 31, 2019 and 2018, the total amount of unrecognized tax benefits due to uncertain tax positions was $76.5 million and $69.1 million, respectively, all of which would affect the effective income tax rate if recognized.
As of March 31, 2019 and 2018, the Company had $36.4 million and $35.0 million, respectively, in non-current income taxes payable, including interest and penalties, related to the Company's income tax liability for uncertain tax positions.
The aggregate changes in gross unrecognized tax benefits in fiscal years 2019, 2018 and 2017 were as follows (in thousands):
March 31, 2016
 
$
69,879

Lapse of statute of limitations
 
(14,161
)
Decreases in balances related to tax positions taken during prior years
 
(1,610
)
Increases in balances related to tax positions taken during the year
 
9,559

March 31, 2017
 
$
63,667

Lapse of statute of limitations
 
(7,505
)
Decreases in balances related to tax positions taken during prior years
 
(704
)
Increases in balances related to tax positions taken during the year
 
13,673

March 31, 2018
 
$
69,131

Lapse of statute of limitations
 
(2,511
)
Decreases in balances related to tax positions taken during prior years
 
(1,550
)
Increases in balances related to tax positions taken during the year
 
11,479

March 31, 2019
 
$
76,549


The Company recognizes interest and penalties related to unrecognized tax positions in income tax expense. The Company recognized $0.6 million, $0.6 million and $0.7 million in interest and penalties in income tax expense during fiscal years 2019, 2018 and 2017, respectively. As of March 31, 2019 and 2018, the Company had $2.5 million and $2.3 million, respectively, of accrued interest and penalties related to uncertain tax positions.
The Company files Swiss and foreign tax returns. The Company received final tax assessments in Switzerland through fiscal year 2017. For other foreign jurisdictions such as the United States, the Company is generally not subject to tax examinations for years prior to fiscal year 2016. The Company is under examination and has received assessment notices in foreign tax jurisdictions. If the examinations are resolved unfavorably, there is a possibility they may have a material negative impact on its results of operations.
Although the Company has adequately provided for uncertain tax positions, the provisions on these positions may change as revised estimates are made or the underlying matters are settled or otherwise resolved. During the next 12 months, it is reasonably possible that the amount of unrecognized tax benefits could increase or decrease significantly due to changes in tax law in various jurisdictions, new tax audits and changes in the U.S. Dollar as compared to other currencies. Excluding these factors, uncertain tax positions may decrease by as much as $3.8 million primarily from the lapse of the statutes of limitations in various jurisdictions during the next 12 months.