Symantec 2012 Annual Report Download - page 125

set forth in this annual report. We have concluded that this positive evidence outweighs the negative evidence
and, thus, that the deferred tax assets as of March 30, 2012 of $528 million, after application of the valuation
allowances described above, are realizable on a “more likely than not” basis.
On December 10, 2009, the U.S. Tax Court issued its opinion in Veritas v. Commissioner, finding that our
transfer pricing methodology, with appropriate adjustments, was the best method for assessing the value of the
transaction at issue between Veritas and its international subsidiary in the 2000 to 2001 tax years. In June 2010,
we reached an agreement with the IRS concerning the amount of the adjustment based on the U.S. Tax Court
decision. As a result of the agreement, we reduced our liability for unrecognized tax benefits, resulting in a $39
million tax benefit in the first quarter of fiscal 2011. In March 2011, we reached agreement with Irish Revenue
concerning compensating adjustments arising from this matter, resulting in an additional $10 million tax benefit
in the fourth quarter of fiscal 2011. This matter has now been closed and no further adjustments to the accrued
liability are expected.
On December 2, 2009, we received a Revenue Agent’s Report from the IRS for the Veritas 2002 through
2005 tax years assessing additional taxes due. We have contested $80 million of the tax assessed and all
penalties. As a result of negotiations with IRS Appeals in the three months ended December 30, 2011, we have
remeasured our liability for unrecognized tax benefits, resulting in a tax benefit of $52 million.
The timing of the resolution of income tax examinations is highly uncertain, and the amounts ultimately
paid, if any, upon resolution of the issues raised by the taxing authorities may differ materially from the amounts
accrued for each year. Although potential resolution of uncertain tax positions involve multiple tax periods and
jurisdictions, it is reasonably possible that a reduction of up to $21 million of the reserves for unrecognized tax
benefits may occur within the next 12 months, some of which, depending on the nature of the settlement or
expiration of statutes of limitations, may affect our income tax provision and therefore benefit the resulting
effective tax rate. The actual amount could vary significantly depending on the ultimate timing and nature of any
settlements.
We continue to monitor the progress of ongoing tax controversies and the impact, if any, of the expected
tolling of the statute of limitations in various taxing jurisdictions.
Loss attributable to noncontrolling interest
In fiscal 2011, we completed the acquisition of the identity and authentication business of VeriSign, Inc.
(“VeriSign”), including a controlling interest in its subsidiary VeriSign Japan K.K. (“VeriSign Japan”), a
publicly traded company on the Tokyo Stock Exchange. Given our majority ownership interest of approximately
54% in VeriSign Japan, the accounts of VeriSign Japan have been consolidated with our accounts, and a
noncontrolling interest has been recorded for the noncontrolling investors’ interests in the equity and operations
of VeriSign Japan. For fiscal 2012 and 2011, the loss attributable to the noncontrolling interest in VeriSign Japan
was approximately $0 million and $4 million, respectively.
LIQUIDITY AND CAPITAL RESOURCES
Sources of cash
We have historically relied on cash flow from operations, borrowings under a credit facility, and issuances
of debt and equity securities for our liquidity needs. As of March 30, 2012, we had cash and cash equivalents of
$3.2 billion.
Senior notes: In the second quarter of fiscal 2011, we issued $350 million in principal amount of 2.75%
notes due September 15, 2015 and $750 million in principal amount of 4.20% notes due September 15, 2020, for
an aggregate principal amount of $1.1 billion.
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