INCOME TAXES | INCOME TAXES Income (loss) before income taxes consists of the following components (in thousands): Fiscal Year 2023 2022 2021 United States $ (466,070) $ 69,938 $ 125,362 Foreign 590,699 1,111,146 682,018 Total $ 124,629 $ 1,181,084 $ 807,380 The components of the income tax provision are as follows (in thousands): Fiscal Year 2023 2022 2021 Current tax (expense) benefit: Federal $ (21,704) $ (16,886) $ (11,043) State (488) (274) (140) Foreign (65,430) (98,696) (80,722) (87,622) (115,856) (91,905) Deferred tax (expense) benefit: Federal 60,351 (18,398) (35,545) State 2,371 (2,762) (3,771) Foreign 3,423 (10,715) 57,452 66,145 (31,875) 18,136 Total $ (21,477) $ (147,731) $ (73,769) A reconciliation of the provision for income taxes to income tax expense computed by applying the statutory federal income tax rate to pre-tax income for fiscal years 2023, 2022 and 2021 is as follows (dollars in thousands): Fiscal Year 2023 2022 2021 Amount Percentage Amount Percentage Amount Percentage Income tax expense at statutory federal rate $ (26,172) 21.0 % $ (248,028) 21.0 % $ (169,550) 21.0 % (Increase) decrease resulting from: State benefit (expense), net of federal impact 2,259 (1.8) (1,888) 0.2 (743) 0.1 Tax credits 97,809 (78.5) 118,877 (10.1) 92,532 (11.5) Effect of changes in income tax rate applied to net deferred tax assets (1) (950) 0.8 (25,679) 2.2 22,286 (2.8) Foreign tax rate difference 73,491 (59.0) 148,932 (12.6) 85,851 (10.6) Foreign permanent differences and related items (10,852) 8.7 786 (0.1) 9,026 (1.1) Change in valuation allowance 385 (0.3) 231 (0.1) (1,232) 0.2 Expiration of state and foreign attributes (1,962) 1.6 (3,048) 0.3 (1,656) 0.2 Stock-based compensation (9,036) 7.2 11,148 (0.9) 9,545 (1.2) Tax reserve adjustments (9,437) 7.6 (3,262) 0.3 (9,979) 1.2 U.S. tax on foreign earnings, including GILTI & FDII (2)(3) (128,708) 103.3 (130,874) 11.1 (100,830) 12.5 Permanent reinvestment assertion (402) 0.3 (1,033) 0.1 (8,488) 1.1 Impairments and acquisition related adjustments (5,695) 4.5 (12,198) 1.0 (919) 0.1 Other income tax (expense) benefit (2,207) 1.8 (1,695) 0.1 388 (0.1) $ (21,477) 17.2 % $ (147,731) 12.5 % $ (73,769) 9.1 % (1) In fiscal 2022, the Company negotiated an extension to its tax holiday in Singapore, resulting in the revaluation of its deferred tax assets. As a result, the Company recognized an income tax expense of $26.4 million due to the reduced tax rate, in part from a reversal of the tax benefit recognized in fiscal 2021. In fiscal 2021, the Company completed the restructuring of the Cavendish intellectual property, resulting in the recognition of an income tax benefit of $22.1 million in Singapore. (2) The Global Intangible Low-Taxed Income ("GILTI") and Foreign-Derived Intangible Income ("FDII") provisions became effective for the Company in fiscal 2019, at which time the Company elected to treat taxes due on future GILTI inclusions in U.S. taxable income as a period cost. (3) Beginning in fiscal 2023 and as required by the Tax Cuts and Jobs Act, the Company was required to capitalize and amortize research and development expenses which were previously expensed for U.S. tax purposes. 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 basis used for income tax purposes. The deferred income tax assets and liabilities are measured in each taxing jurisdiction using the enacted tax rates and laws that will be in effect when the differences are expected to reverse. Significant components of the Company’s net deferred income taxes are as follows (in thousands): April 1, 2023 April 2, 2022 Deferred income tax assets: Research and other tax credits $ 57,048 $ 56,735 Employee benefits 30,309 34,189 Inventories 24,374 11,592 Net operating loss carryforwards 22,189 27,024 Lease liabilities 18,768 17,905 Prepaid expenses 17,360 — Deferred revenue 14,475 — Capitalized research and development expenses 13,794 6,040 Other 15,898 10,332 Total deferred income tax assets 214,215 163,817 Valuation allowance (35,896) (36,281) Total deferred income tax assets, net of valuation allowance $ 178,319 $ 127,536 Deferred income tax liabilities: Intangible assets $ (69,050) $ (79,452) Property and equipment (39,806) (53,425) Accrued tax on unremitted foreign earnings (25,948) (22,988) Right-of-use assets (17,457) (16,591) Other (2,645) (2,884) Total deferred income tax liabilities (154,906) (175,340) Net deferred income tax asset (liability) $ 23,413 $ (47,804) Amounts included in the Consolidated Balance Sheets: Other non-current assets $ 38,060 $ 36,824 Other long-term liabilities (14,647) (84,628) Net deferred income tax asset (liability) $ 23,413 $ (47,804) The Company has recorded a valuation allowance against certain U.S. and foreign deferred tax assets as of April 1, 2023 and April 2, 2022. These valuation allowances were established based upon management's opinion that it is more likely than not (a likelihood of more than 50 percent) that the benefit of these deferred tax assets will not be realized. The valuation allowance against deferred tax assets decreased in fiscal years 2023 and 2022 by $0.4 million and $0.2 million, respectively, and increased in fiscal 2021 by $1.2 million. The components of the change in valuation allowances and ending balances are as follows (in thousands): Fiscal Year 2023 2022 2021 Beginning valuation allowance $ 36,281 $ 36,512 $ 35,280 Domestic net operating losses and credits 583 1,339 2,144 Foreign net operating losses and other deferred tax assets (968) (1,570) (912) Ending valuation allowance $ 35,896 $ 36,281 $ 36,512 Components of ending valuation allowance: Domestic deferred tax assets $ 35,570 $ 34,987 $ 33,647 Foreign deferred tax assets 326 1,294 2,865 Valuation allowance $ 35,896 $ 36,281 $ 36,512 As of April 1, 2023, the Company had federal tax loss carryforwards of approximately $32.1 million that expire in fiscal years 2024 to 2043, if unused, and state tax loss carryforwards of approximately $107.9 million that expire in fiscal years 2024 to 2043, if unused. Federal research credits of $102.8 million expire in fiscal years 2040 to 2043, and state research credits of $68.3 million expire in fiscal years 2024 to 2043. The Company had foreign tax loss carryforwards of $96.4 million, which expire in fiscal years 2024 to 2033, if unused. The utilization of acquired domestic tax assets is subject to certain annual limitations as required under Section 382 of the Internal Revenue Code of 1986, as amended (the "Code") and similar state income tax provisions. The Company has continued to expand its operations and increase its investments in numerous international jurisdictions. These activities expose the Company to taxation in multiple foreign jurisdictions. As a result, management has concluded that it is not permanently reinvested on certain earnings of its foreign subsidiaries which have been subject to U.S. federal taxation. The remainder of the Company's untaxed foreign earnings and historic investments will continue to be permanently reinvested to fund working capital requirements and operations abroad. It is not practical to estimate the additional tax that would be incurred, if any, if the remainder of the permanently reinvested earnings were repatriated. The Company has foreign subsidiaries with tax holiday agreements in Costa Rica and Singapore. The Company’s tax holiday in Costa Rica is set to expire in December 2027. In fiscal 2022, the Company negotiated an extension to its tax holiday in Singapore, which is currently expected to expire in December 2031. Incentives from these countries are subject to the Company meeting certain employment and investment requirements. Relative to the statutory tax rate, income tax expense decreased by $65.5 million (an impact of approximately $0.64 per basic and diluted share) in fiscal 2023 and $128.4 million (an impact of approximately $1.17 and $1.15 per basic and diluted share, respectively) in fiscal 2022 as a result of these agreements. The Company’s gross unrecognized tax benefits totaled $152.3 million, $144.1 million and $134.1 million as of April 1, 2023, April 2, 2022, and April 3, 2021, respectively. Of these amounts, $145.9 million, $137.5 million and $128.7 million as of April 1, 2023, April 2, 2022 and April 3, 2021, respectively, represent the amounts of unrecognized tax benefits that, if recognized, would impact the effective tax rate in each of the fiscal years. The Company’s gross unrecognized tax benefits increased from $144.1 million as of April 2, 2022 to $152.3 million as of April 1, 2023, primarily due to current year tax positions and the effect of provision-to-return adjustments on prior year positions. A summary of the changes in the amount of gross unrecognized tax benefits is as follows (in thousands): Fiscal Year 2023 2022 2021 Beginning balance $ 144,055 $ 134,068 $ 119,222 Additions based on positions related to current year 9,718 11,826 10,048 Additions for tax positions in prior years 2,467 3,049 6,240 Reductions for tax positions in prior years (363) (1,669) (348) Expiration of statute of limitations (3,546) (3,219) (1,094) Settlements — — — Ending balance $ 152,331 $ 144,055 $ 134,068 It is the Company’s policy to recognize interest and penalties related to uncertain tax positions as a component of income tax expense. During fiscal years 2023, 2022 and 2021, the Company recognized $0.9 million, $(5.1) million and $0.8 million, respectively, of interest and penalties related to uncertain tax positions. Accrued interest and penalties related to unrecognized tax benefits totaled $1.9 million, $1.0 million and $6.2 million as of April 1, 2023, April 2, 2022 and April 3, 2021, respectively. The unrecognized tax benefits of $152.3 million and accrued interest and penalties of $1.9 million at the end of fiscal 2023 are recorded on the Consolidated Balance Sheet as a $21.0 million other long-term liability, with the balance reducing the carrying value of the gross deferred tax assets. Due to uncertainties regarding the timing of examinations and the amount of settlements that may be paid, if any, to tax authorities, the Company believes it is reasonably possible that $22.1 million of gross unrecognized tax benefits will be reduced within the next 12 months. The Company files a consolidated U.S. federal income tax return, as well as separate and combined income tax returns in numerous state and international jurisdictions. The Company’s fiscal 2020 U.S. federal and state tax returns and subsequent tax years remain open for examination, as well as all attributes brought forward into those years. The Company is also subject to examination by various international tax authorities. The tax years subject to examination vary by jurisdiction. |