Income Taxes | Income Taxes Income tax provision Income (loss) before income taxes and the income tax (expense) benefit includes the following (in thousands): Fiscal Year Ended March 31, 2021 2020 2019 Domestic $ 37,368 $ (245,177) $ (163,385) Foreign 40,485 26,644 23,474 Total $ 77,853 $ (218,533) $ (139,911) The income tax provision includes the following (in thousands): Fiscal Year Ended March 31, 2021 2020 2019 Income tax expense (benefit) Federal $ (3,835) $ 180,402 $ 3,213 State (2,071) 48,045 575 Foreign 15,110 13,058 5,920 Total current tax position 9,204 241,505 9,708 Federal (3,027) (37,731) (29,021) State (615) (5,689) (5,464) Foreign (3,423) (2,801) 1,060 Total deferred tax provision (7,065) (46,221) (33,425) Total income tax expense (benefit) $ 2,139 $ 195,284 $ (23,717) The Company’s income tax expense of $2.1 million for the year ended March 31, 2021 differed from the amount computed on pre-tax income at the U.S. federal income tax rate of 21%, primarily due to the impact of tax return to provision true-ups resulting from changes in estimates to the reorganization transaction tax and the corresponding impact to the uncertain tax positions. In addition, the difference was due to the vesting of share-based compensation that generated excess tax benefits, the foreign-derived intangible income deduction, and the utilization of U.S. foreign tax credits generated in the current year as well as the carryforward from previous years. The Company’s income tax expense of $195.3 million for the year ended March 31, 2020 differed from the amount computed on pre-tax loss at the U.S. federal income tax rate of 21% because of the effects of the reorganization transaction, non-deductible share-based compensation, and the foreign-derived intangible income deduction. The transaction produced a gain on the difference between the fair market value of the Compuware assets distributed and the adjusted tax basis in such assets, generating a tax liability that was only partially offset by U.S. foreign tax credits that previously were subject to a valuation allowance. The Company’s income tax benefit of $23.7 million for the year ended March 31, 2019 differed from the amount computed on pre-tax loss at the U.S. federal income tax rate of 21% primarily because of non-deductible share-based compensation, the effects of which were partially offset by U.S. tax credits generated during this year as well as the foreign-derived intangible income deduction. The tax rate reconciliation is as follows (in thousands, certain prior year amounts have been reclassified to conform to the current year’s presentation): Fiscal Year Ended March 31, 2021 2020 2019 Income tax expense (benefit) at U.S. federal statutory income tax rate $ 16,349 $ (45,892) $ (29,381) State and local tax expense (580) (2,897) (4,890) Foreign tax rate differential 1,939 3,521 2,051 Branch income 4,830 1,601 1,824 Non-deductible expenses 3,459 5,976 840 Tax credits (9,316) (57,277) (13,233) Foreign derived intangibles deduction (4,775) (3,901) (1,790) Tax associated with reorganization — 239,990 — Share-based compensation (6,424) 48,129 10,967 Prior year tax return to provision true-ups (11,464) — — Changes in uncertain tax positions (1,102) 13,204 234 Changes in valuation allowance 2,091 (9,472) 6,087 Foreign withholding tax 6,992 4,231 3,086 Other adjustments 140 (1,929) 488 Total income tax expense (benefit) $ 2,139 $ 195,284 $ (23,717) Deferred tax assets and liabilities Management assesses the available positive and negative evidence to estimate if sufficient future taxable income will be generated to use the existing deferred tax assets. A significant piece of objective negative evidence evaluated was the jurisdictional cumulative loss incurred over the three-year period ended March 31, 2021. Such objective evidence limits the ability to consider other subjective evidence such as the Company’s projections for future growth. Based on this evaluation, a valuation allowance of $24.3 million and $22.2 million has been recorded as of March 31, 2021 and 2020, respectively. Only the portion of the deferred tax asset that is more likely than not to be realized has been recorded. Given the Company’s current earnings and anticipated future earnings, it is reasonably possible that within the next twelve months sufficient positive evidence may become available to allow the Company to conclude that a significant portion of the valuation allowance will no longer be needed. Release of the valuation allowance would result in the recognition of certain deferred tax assets. However, the exact timing and amount of the valuation allowance release are subject to change based on the Company’s growth and profitability. Temporary differences and carryforwards that give rise to a significant portion of deferred tax assets and liabilities are as follows (in thousands, certain prior year amounts have been reclassified to conform to the current year’s presentation): March 31, 2021 2020 Deferred revenue $ 17,050 $ 23,185 Capitalized research and development costs 10,834 11,140 Accrued expenses 8,882 6,217 Share-based compensation 8,367 5,251 Lease liabilities 8,321 — Net operating loss carryforwards 4,637 4,468 Other tax carryforwards, primarily foreign tax credits 20,479 18,215 Other 2,272 2,590 Total deferred tax assets before valuation allowance 80,842 71,066 Less: valuation allowance (24,297) (22,206) Net deferred tax assets 56,545 48,860 Intangible assets 30,525 40,270 Right-of-use assets 7,388 — Other 2,835 1,185 Total deferred tax liabilities 40,748 41,455 Net deferred tax assets $ 15,797 $ 7,405 At March 31, 2021, the Company had non-U.S. net operating loss carryforwards of $22.8 million of which $1.8 million expires in periods through 2033 if not utilized, and the remaining balance of $21.0 million may be carried forward indefinitely. The Company had U.S. net operating loss carryforwards and tax credit carryforwards of $21.5 million which expire in periods through 2040 if not utilized. The Company has not provided for taxes on the excess of the amount for financial reporting over the tax basis of investments in foreign subsidiaries that is indefinitely reinvested. Generally, these earnings will be treated as previously taxed income from either the one-time transition tax or GILTI (“Global Intangible Low Taxed Income”), or they will be offset with a 100% dividend received deduction. The income taxes applicable to repatriating such earnings are not readily determinable. As of March 31, 2021, the Company had no plans which would subject these basis differences to income taxes in the United States or elsewhere. Uncertain tax positions The amount of gross unrecognized tax benefits was $15.1 million and $16.6 million as of March 31, 2021 and 2020, respectively, all of which would favorably affect the Company’s effective tax rate if recognized in future periods. The following is a tabular reconciliation of the total amounts of unrecognized tax benefits for the years ended March 31, 2021, 2020, and 2019 (in thousands): Fiscal Year Ended March 31, 2021 2020 2019 Gross unrecognized tax benefit, beginning of year $ 16,648 $ 9,653 $ 9,143 Gross increases to tax positions for prior periods 1,223 438 20 Gross decreases to tax positions for prior periods (2,654) (6,986) (70) Gross increases to tax positions for current period — 13,543 560 Settlements (10) — — Lapse of statutes of limitations (132) — — Gross unrecognized tax benefit, end of year $ 15,075 $ 16,648 $ 9,653 As of March 31, 2021 and 2020, the net interest and penalties payable associated with its uncertain tax positions was $0.9 million and $0.3 million, respectively. During the years ended March 31, 2021 and 2020, the Company recognized expense related to interest and penalties of $0.6 million and $0.2 million, respectively. During the year ended March 31, 2019, the Company recognized an immaterial amount of net interest expense. The Company files tax returns in the U.S. federal, state, and foreign jurisdictions and the tax returns are subject to examination by various domestic and international tax authorities. As of March 31, 2021, the Internal Revenue Services has completed the examinations of the Company’s fiscal 2018 federal income tax return. The settlement from this examination was not material to the Company’s financial statements, including cash flow and effective tax rate. The Company has open years in all significant federal, state, and foreign jurisdictions back to 2011 in certain locations. These open years contain matters that could be subject to differing interpretations of applicable tax laws and regulations due to the amount, timing or inclusion of revenue and expenses. The Company does not anticipate a significant impact to the gross unrecognized tax benefits within the next twelve months related to these open years. Tax legislation On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was signed into law. The CARES Act, among other things, includes provisions relating to refundable payroll tax credits, deferment of employer side social security payments, net operating loss carryback periods, alternative minimum tax credit refunds, modifications to the net interest deduction limitations, increased limitations on qualified charitable contributions, and technical corrections to tax depreciation methods for qualified improvement property. The Company is required to recognize the effects of tax law changes in the period of enactment. The CARES Act did not materially impact the Company’s tax provision as of March 31, 2021 and 2020. Immaterial revision of previously issued consolidated financial statements During the fourth quarter of fiscal 2021, in conjunction with the Company’s completion of the tax return to provision process, the Company identified an immaterial error in the calculation of its income tax provision for the year ended March 31, 2020. The error was primarily related to adjustments to tax attributes related to the reorganization and stock-based compensation. The Company evaluated the materiality of the error, considering both quantitative and qualitative factors, and determined that the related impact was not material to its consolidated financial statements for the year ended March 31, 2020, the three months ended June 30, 2020, the three and six months ended September 30, 2020, and the three and nine months ended December 31, 2020. The Company has decided to correct the prior year presentation to provide comparability to the fiscal 2021 consolidated financial statements. Accordingly, the results for the year ended March 31, 2020 have been adjusted to incorporate the revised amounts, where applicable. The adjustments below related to the consolidated balance sheet as of March 31, 2020 are also required for June 30, 2020, September 30, 2020, and December 31, 2020. The following tables summarize the effect of this revision (in thousands, except per share data): March 31, 2020 As Previously Reported Adjustment As Revised Consolidated Balance Sheets Items: Prepaid expenses and other current assets $ 61,188 $ 17,852 $ 79,040 Total current assets 469,925 17,852 487,777 Deferred tax assets, net 20,460 (13,055) 7,405 Total assets 2,042,080 4,797 2,046,877 Accrued expenses, current 93,728 1,283 95,011 Total current liabilities 488,900 1,283 490,183 Accrued expenses, non-current 20,987 (693) 20,294 Total liabilities 1,080,583 590 1,081,173 Accumulated deficit (594,026) 4,207 (589,819) Total shareholders’ equity 961,497 4,207 965,704 Total liabilities and shareholders’ equity $ 2,042,080 $ 4,797 $ 2,046,877 Fiscal Year Ended March 31, 2020 As Previously Reported Adjustment As Revised Consolidated Statements of Operations Items: Income tax expense $ (199,491) $ 4,207 $ (195,284) Net loss (418,024) 4,207 (413,817) Net loss per share: Basic and diluted $ (1.58) $ 0.02 $ (1.56) Fiscal Year Ended March 31, 2020 As Previously Reported Adjustment As Revised Consolidated Statements of Comprehensive Income (Loss) Items: Net loss $ (418,024) $ 4,207 $ (413,817) Comprehensive loss $ (406,419) $ 4,207 $ (402,212) March 31, 2020 As Previously Reported Adjustment As Revised Consolidated Statements of Shareholders’ Equity / Member’s Deficit Items: Net loss $ (418,024) $ 4,207 $ (413,817) Total shareholders’ equity, balance at March 31, 2020 $ 961,497 $ 4,207 $ 965,704 Fiscal Year Ended March 31, 2020 As Previously Reported Adjustment As Revised Consolidated Statements of Cash Flow Items: Net loss $ (418,024) $ 4,207 $ (413,817) Deferred income taxes (59,276) 13,055 (46,221) Prepaid expenses and other assets (39,737) (17,851) (57,588) Accounts payable and accrued expenses 52,415 589 53,004 Net cash used in operating activities $ (142,455) $ — $ (142,455) The following table represents revisions to the Company’s current and deferred tax expense (in thousands): |