Income Taxes |
3 Months Ended |
|---|---|
Jan. 31, 2017 | |
| Income Tax Disclosure [Abstract] | |
| Income Taxes | Income Taxes We recorded tax provisions totaling $2.9 million and $2.0 million for the three months ended January 31, 2017 and 2016, respectively. The income tax provisions for the three months ended January 31, 2017 and 2016 are primarily related to foreign taxes partially offset by the reversal of unrecognized tax benefits where statute of limitations expired or audits have been settled. Our total unrecognized tax benefits were approximately $106.5 million as of January 31, 2017. The amount of unrecognized tax benefits could be reduced upon closure of tax examinations or if the statute of limitations on certain tax filings expires without assessment from the relevant tax authorities. We believe that it is reasonably possible that there could be an immaterial reduction in unrecognized tax benefits due to statute of limitation expirations in multiple tax jurisdictions during the next 12 months. Interest and penalties accrued on these uncertain tax positions will also be released upon the expiration of the applicable statute of limitations. Israel Tax Audit Assessment We are currently under audit by the Israeli Tax Authorities for fiscal years 2008 through 2009 and 2011 through 2013. The Israeli Tax Authorities issued a tax assessment in October 2014 for fiscal year 2009 or alternatively for fiscal year 2008 claiming there was a business restructuring that resulted in a transfer of some functions, assets and risks from VeriFone Israel Ltd. to the U.S. parent company that the Israeli Tax Authorities claim was a sale valued at 1.36 billion New Israeli Shekels (approximately $361.4 million at the foreign exchange rate as of January 31, 2017). We filed our objection to the tax assessment in January 2015 and received the Israeli Tax Authorities decision through an Order (a second stage assessment) in January 2016. The Order increased the value of the sale to 2.20 billion New Israeli Shekels in fiscal year 2009 (approximately $584.2 million at the foreign exchange rate as of January 31, 2017) or alternatively 2.23 billion New Israeli Shekels in fiscal year 2008 (approximately $591.0 million at the foreign exchange rate as of January 31, 2017) and contended secondary adjustments relating to a deemed dividend and/or interest. Based on the Order, these and other claims result in a tax liability and deficiency penalty assessment in the amount of 1.29 billion New Israeli Shekels (approximately $341.8 million at the foreign exchange rate as of January 31, 2017), if the claim was assessed for fiscal year 2009, to 1.53 billion New Israeli Shekels (approximately $405.4 million at the foreign exchange rate as of January 31, 2017) if the claim was assessed for fiscal year 2008, including interest, the required Israeli price index adjustments (referred to as the linkage differentials) and deficiency fines (as applicable) through January 31, 2017. The Israeli Tax Authorities' contention regarding secondary adjustments relating to deemed dividend was not quantified by them. We continue to believe the Israeli Tax Authorities' assessment position is without merit and appealed the assessment to the district court. We have agreed with the Israeli Tax Authorities to repay our $69.0 million intercompany loan from VeriFone Israel Ltd. to the extent of the amount of a final agreed tax assessment concerning fiscal year 2008 and fiscal year 2009 or a judgment of a district court in an appeal on the decision of the Israeli Tax Authorities in the objection, if any. Other Audits We have certain other foreign subsidiaries under audit by foreign tax authorities, including India for fiscal years 2008 to 2015, Spain for fiscal years 2011 to 2013 and New Zealand for fiscal years 2014 and 2015. Although we believe we have appropriately provided for income taxes for the years subject to audit, the India, Israel, Spain and New Zealand taxing authorities may adopt different interpretations. We have not yet received any final determinations with respect to these audits. We have accrued tax liabilities associated with these audits. With few exceptions, we are no longer subject to tax examination for periods prior to 2008. |