v3.24.3
Income Taxes
12 Months Ended
Sep. 30, 2024
Income Tax Disclosure [Abstract]  
Income Taxes
15.
Income Taxes

The provision for income taxes for the fiscal years 2024, 2023 and 2022 consists of the following (in thousands):

 

 

 

Fiscal Year Ended September 30,

 

 

2024

 

 

2023

 

 

2022

 

Current:

 

 

 

 

 

 

 

 

 

Federal

 

$

35,897

 

 

$

42,103

 

 

$

48,888

 

Foreign

 

 

10,393

 

 

 

7,317

 

 

 

16,370

 

State

 

 

8,004

 

 

 

9,830

 

 

 

10,739

 

Total current portion

 

 

54,294

 

 

 

59,250

 

 

 

75,997

 

Deferred:

 

 

 

 

 

 

 

 

 

Federal

 

 

(3,149

)

 

 

3,299

 

 

 

93

 

Foreign

 

 

1,116

 

 

 

3,233

 

 

 

(15,380

)

State

 

 

650

 

 

 

1,668

 

 

 

(166

)

Total deferred portion

 

 

(1,383

)

 

 

8,200

 

 

 

(15,453

)

Total provision for income taxes

 

$

52,911

 

 

$

67,450

 

 

$

60,544

 

 

The difference between the U.S. statutory federal income tax rate and the effective income tax rate is summarized below:

 

 

 

Fiscal Year Ended September 30,

 

 

 

 

2024

 

 

 

2023

 

 

 

2022

 

 

U.S. federal statutory income tax rate

 

 

21.0

 

%

 

 

21.0

 

%

 

 

21.0

 

%

State income taxes, net of federal tax benefit

 

 

3.0

 

 

 

 

3.4

 

 

 

 

2.6

 

 

Effect of foreign operations

 

 

1.2

 

 

 

 

1.3

 

 

 

 

2.2

 

 

Repatriation Tax

 

 

—

 

 

 

 

1.1

 

 

 

 

—

 

 

Share-based payment awards

 

 

0.4

 

 

 

 

0.5

 

 

 

 

0.6

 

 

Unrecognized tax benefit

 

 

0.3

 

 

 

 

0.3

 

 

 

 

2.9

 

 

Valuation allowances

 

 

0.1

 

 

 

 

0.1

 

 

 

 

(7.2

)

 

Deferred tax impact of foreign branch conversion

 

 

—

 

 

 

 

—

 

 

 

 

2.7

 

 

Other, net

 

 

(0.4

)

 

 

 

(0.9

)

 

 

 

—

 

 

Effective tax rate

 

 

25.6

 

%

 

 

26.8

 

%

 

 

24.8

 

%

The tax effects of temporary differences that give rise to our deferred tax assets and liabilities are as follows (in thousands):

 

 

 

September 30,

 

 

2024

 

 

2023

 

Deferred tax assets attributable to:

 

 

 

 

 

 

Foreign loss carryforwards

 

$

28,713

 

 

$

32,435

 

U.S. foreign tax credits

 

 

13,279

 

 

 

12,913

 

Accrued liabilities

 

 

10,604

 

 

 

17,672

 

Share-based compensation expense

 

 

8,323

 

 

 

7,430

 

Other

 

 

(785

)

 

 

(2,937

)

Total deferred tax assets

 

 

60,134

 

 

 

67,513

 

Valuation allowance

 

 

(34,298

)

 

 

(35,912

)

Total deferred tax assets, net

 

 

25,836

 

 

 

31,601

 

Deferred tax liabilities attributable to:

 

 

 

 

 

 

Depreciation and amortization

 

 

95,377

 

 

 

101,957

 

Inventory adjustments

 

 

418

 

 

 

1,452

 

Total deferred tax liabilities

 

 

95,795

 

 

 

103,409

 

Net deferred tax liability

 

$

69,959

 

 

$

71,808

 

We believe that it is more-likely-than-not that the results of future operations will generate sufficient taxable income to realize the deferred tax assets, net of the valuation allowance. During fiscal year 2024, existing valuation allowances were decreased by approximately $1.6 million, primarily for net operating loss carry-forwards of various members of the affiliated group in foreign jurisdictions and foreign tax credits. We continue to record a valuation allowance to account for uncertainties regarding recoverability of certain deferred tax assets, primarily foreign loss carry-forwards and tax credit carry-forwards.

Domestic earnings before provision for income taxes were $175.2 million, $217.7 million and $205.2 million in the fiscal years 2024, 2023 and 2022, respectively. Foreign earnings before provision for income taxes of $31.1 million, $34.4 million and $38.9 million in the fiscal years 2024, 2023 and 2022, respectively.

Tax reserves are evaluated and adjusted as appropriate, while taking into account the progress of audits by various taxing jurisdictions and other changes in relevant facts and circumstances evident at each balance sheet date. We do not expect the outcome of current or future tax audits to have a material adverse effect on our consolidated financial condition, results of operations or cash flow.

Applicable deferred tax liabilities have been provided for undistributed foreign earnings in excess of foreign working capital and cash requirements. As a result of U.S. Tax Reform, the repatriation of cash to the U.S. is generally no longer taxable for federal income tax purposes but could be subject to foreign withholding taxes and state income taxes. If undistributed earnings of our foreign operations were not considered permanently reinvested as of September 30, 2024, an immaterial amount of additional deferred taxes would have been provided.

At September 30, 2024 and 2023, we had total operating loss carry-forwards of $106.6 million and $119.4 million, respectively, of which $52.5 million and $62.7 million, respectively, are subject to a valuation allowance. At September 30, 2024, operating loss carry-forwards of $106.6 million have no expiration date. At September 30, 2024 and 2023, we had tax credit carry-forwards of $15.2 million and $15.5 million, respectively. This includes a U.S. foreign tax credit carry-forward of $13.3 million, primarily as a result of the deemed repatriation tax under U.S. Tax Reform. This credit expires in 2028. We do not believe the realization of the U.S. foreign tax credit is more-likely-than-not, so a valuation allowance has been recorded against its full value. Of the remaining tax credit carry-forwards, at September 30, 2024, $0.3 million expire between 2025 and 2029, $0.3 million expire between 2033 and 2037 and $1.3 million have no expiration date. Total tax credit carry-forwards of $14.8 million and $14.2 million are subject to a valuation allowance at September 30, 2024 and 2023, respectively.

The changes in the amount of unrecognized tax benefits are as follows (in thousands):

 

 

 

Fiscal Year Ended September 30,

 

 

 

2024

 

 

2023

 

Balance at beginning of the fiscal year

 

$

8,312

 

 

$

9,165

 

Increases related to prior year tax positions

 

 

7

 

 

 

1,983

 

Decreases related to prior year tax positions

 

 

(19

)

 

 

(128

)

Increases related to current year tax positions

 

 

602

 

 

 

759

 

Decreases due to settlements

 

 

(414

)

 

 

(3,337

)

Lapse of statute

 

 

(90

)

 

 

(130

)

Balance at end of fiscal year

 

$

8,398

 

 

$

8,312

 

If recognized, these positions would affect our effective tax rate.

On December 22, 2017, the Tax Cuts and Jobs Act (“TCJA”) enacted comprehensive amendments to the Internal Revenue Code of 1986. Among other things, TCJA provided for a deemed repatriation of undistributed foreign earnings by U.S. taxpayers giving rise to a one-time transition tax on those earnings (“Repatriation Tax”). The U.S. Treasury Department issued final regulations (“Regulations”) addressing certain aspects of how the Repatriation Tax is calculated. In our view, certain guidance included in the Regulations is inconsistent with our interpretation of the statutory language contained in the TCJA. In fiscal year 2023, we remitted $4.3 million in tax and interest to the IRS. Income tax expense of $2.7 million was recorded in fiscal year 2023 related to the payments. Previously, $1.6 million had been reserved for this issue. We maintain our tax positions are fully supportable.

We recognize interest and penalties, accrued in connection with unrecognized tax benefits, in provision for income taxes. Accrued interest and penalties, in the aggregate, were $0.7 million and $0.5 million at September 30, 2024 and 2023, respectively.

Because existing tax positions will continue to generate increased liabilities for unrecognized tax benefits over the next 12 months, and the fact that from time to time our tax returns are routinely under audit by various taxing authorities, it is reasonably possible that the amount of unrecognized tax benefits will change during the next 12 months. An estimate of the amount of such change, or a range thereof, cannot reasonably be made at this time. However, we do not expect the change, if any, to have a material effect on our consolidated financial condition or results of operations within the next 12 months.

Our consolidated federal income tax return for the fiscal years 2022 and 2023 are currently under IRS examination. Our statute remains open for the fiscal year ended September 30, 2021, forward. Our U.S. state income tax returns are impacted by various statutes of limitations and are generally open for the fiscal year ended September 30, 2021, and future years. Our foreign income tax returns are impacted by various statutes of limitations, which are generally open from 2019 forward.

 

In December of 2021, the Organization for Economic Cooperation and Development (OECD) established a framework, referred to as Pillar 2, designed to ensure large multinational enterprises pay a minimum 15 percent level of tax on the income arising in each jurisdiction in which they operate. The earliest effective date is for taxable years beginning after December 31, 2023, which for us is fiscal year 2025. Numerous countries have already enacted the OECD model rules, and several other countries have drafted legislation. We do not expect this legislation to have a

material impact on our consolidated financial statements. We will continue to monitor and evaluate new legislation and guidance, which could change our current assessment.