Symantec 2014 Annual Report Download - page 172

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As of March 28, 2014, no provision has been made for federal or state income taxes on $3.2 billion of
cumulative unremitted earnings of certain of our foreign subsidiaries since we plan to indefinitely reinvest these
earnings. As of March 28, 2014, the unrecognized deferred tax liability for these earnings was $918 million.
The aggregate changes in the balance of gross unrecognized tax benefits from April 1, 2011 to March 28,
2014 were as follows (in millions):
Balance as of April 1, 2011 $ 527
Settlements and effective settlements with tax authorities and related remeasurements (62)
Lapse of statute of limitations (12)
Increases in balances related to tax positions taken during prior years 78
Decreases in balances related to tax positions taken during prior years (30)
Increases in balances related to tax positions taken during current year 118
Balance as of March 30, 2012 $ 619
Settlements and effective settlements with tax authorities and related remeasurements (114)
Lapse of statute of limitations (98)
Increases in balances related to tax positions taken during prior years 11
Decreases in balances related to tax positions taken during prior years (20)
Increases in balances related to tax positions taken during current year 14
Balance as of March 29, 2013 $ 412
Settlements and effective settlements with tax authorities and related remeasurements (122)
Lapse of statute of limitations (11)
Increases in balances related to tax positions taken during prior years 27
Decreases in balances related to tax positions taken during prior years (50)
Increases in balances related to tax positions taken during current year 26
Balance as of March 28, 2014 $ 282
There was a change of $130 million in gross unrecognized tax benefits during the fiscal year as disclosed
above. This gross liability does not include offsetting tax benefits associated with the correlative effects of
potential transfer pricing adjustments, interest deductions, and state income taxes, as well as payments made to
date.
Of the total unrecognized tax benefits at March 28, 2014, $284 million, if recognized, would favorably
affect the Company’s effective tax rate, while $2 million would affect the cumulative translation adjustments.
However, one or more of these unrecognized tax benefits could be subject to a valuation allowance if and when
recognized in a future period, which could impact the timing of any related effective tax rate benefit.
At March 28, 2014, before any tax benefits, we had $51 million of accrued interest and penalties on
unrecognized tax benefits. Interest included in our provision for income taxes was an expense of approximately
$7 million, offset by reductions of $3 million for the year ended March 28, 2014. If the accrued interest and
penalties do not ultimately become payable, amounts accrued will be reduced in the period that such
determination is made, and reflected as a reduction of the overall income tax provision.
We file income tax returns in the U.S. on a federal basis and in many U.S. state and foreign jurisdictions.
Our most significant tax jurisdictions are the U.S., Ireland, and Singapore. Our tax filings remain subject to
examination by applicable tax authorities for a certain length of time following the tax year to which those filings
relate. Our 2009 through 2014 fiscal years remain subject to examination by the Internal Revenue Service
(“IRS”) for U.S. federal tax purposes, our 2010 through 2014 fiscal years remain subject to examination by the
appropriate governmental agencies for Irish tax purposes, and our 2007 through 2014 fiscal years remain subject
93