Income Taxes
Income (loss) before income taxes consisted of (in thousands): | | | | | | | | | | | | | | | | | | | | |
| | | Fiscal Years Ended |
| | March 28, 2026 | | March 29, 2025 | | March 30, 2024 |
| U.S. | | $ | 1,601 | | | $ | 538 | | | $ | (10,343) | |
| Non-U.S. | | 495,133 | | | 444,376 | | | 374,279 | |
| | $ | 496,734 | | | $ | 444,914 | | | $ | 363,936 | |
The provision (benefit) for income taxes consists of (in thousands):
| | | | | | | | | | |
| | Fiscal Year Ended | | |
| | March 28, 2026 | | |
| Current: | | | | |
| U.S. Federal | | $ | 5,578 | | | |
| U.S. State and Local | | (116) | | | |
| Non-U.S. | | 77,996 | | | |
| Total Current | | $ | 83,458 | | | |
| Deferred: | | | | |
| U.S. Federal | | 2,265 | | | |
| U.S. State and Local | | 280 | | | |
| Non-U.S. | | (3,677) | | | |
| Total Deferred | | (1,132) | | | |
| Provision for Income Taxes | | $ | 82,326 | | | |
| | | | | | | | | | | | | | |
| | | Fiscal Years Ended |
| | March 29, 2025 | | March 30, 2024 |
| Current: | | | | |
| U.S. | | $ | 39,932 | | | $ | 42,184 | |
| Non-U.S. | | 73,573 | | | 60,615 | |
| Total Current | | $ | 113,505 | | | $ | 102,799 | |
| Deferred: | | | | |
| U.S. | | 1,575 | | | (5,178) | |
| Non-U.S. | | (1,673) | | | (8,257) | |
| Total Deferred | | (98) | | | (13,435) | |
| Provision for Income Taxes | | $ | 113,407 | | | $ | 89,364 | |
The effective income tax rates differ from the rates computed by applying the statutory federal rate to pretax income as follows (in percentages):
| | | | | | | | | | | | | | |
| | | Fiscal Year Ended |
| | March 28, 2026 |
| | Amount | | Percent |
| U.S. federal tax at statutory rate | | $ | 104,314 | | | 21.0 | % |
State and local income taxes, net of federal income tax effect (1) | | 227 | | | 0.1 | % |
| Foreign tax effects: | | | | |
| United Kingdom | | | | |
| Statutory tax rate difference | | 19,761 | | | 4.0 | % |
| Patent box incentive benefit | | (42,066) | | | (8.5) | % |
| Stock-based compensation | | (7,352) | | | (1.5) | % |
| Other | | 191 | | | — | % |
| Other foreign jurisdictions | | 1,433 | | | 0.3 | % |
| | | | |
| Effect of cross-border tax laws: | | | | |
| GILTI and Subpart F income, net of foreign tax credit | | 1,765 | | | 0.4 | % |
| | | | |
| | | | |
| | | | |
| Nontaxable or nondeductible items | | 3,239 | | | 0.7 | % |
| Changes in unrecognized tax benefits | | 2,681 | | | 0.5 | % |
| Other adjustments | | (1,867) | | | (0.4) | % |
| Effective Tax Rate | | $ | 82,326 | | | 16.6 | % |
(1) State income taxes in California comprise the majority of the effect of the state and local income tax category.
| | | | | | | | | | | | | | |
| | | Fiscal Years Ended |
| | March 29, 2025 | | March 30, 2024 |
| U.S. federal statutory rate | | 21.0 | % | | 21.0 | % |
| Foreign income taxed at different rates | | (3.5) | % | | (7.1) | % |
| Stock-based compensation | | (1.7) | % | | (0.1) | % |
| Foreign-derived intangible income deduction | | — | % | | (0.2) | % |
| GILTI and Subpart F income | | 14.1 | % | | 14.6 | % |
| Foreign tax credits | | (5.6) | % | | (4.1) | % |
| | | | |
| Release of prior year unrecognized tax benefits | | — | % | | (0.2) | % |
| Interest related to unrecognized tax benefits | | 0.6 | % | | 0.7 | % |
| U.S. research and development credit | | — | % | | (0.7) | % |
| Other | | 0.6 | % | | 0.7 | % |
| Effective tax rate | | 25.5 | % | | 24.6 | % |
The One Big Beautiful Bill Act ("OBBBA"), enacted on July 4, 2025, included a broad range of tax reform provisions and extended or modified many provisions first enacted in the Tax Cuts and Jobs Act ("TCJA") in 2017. Beginning with fiscal year 2026, the OBBBA permanently eliminated the TCJA's requirement to capitalize U.S. research and development ("R&D") expenditures. A number of other provisions, including modifications to existing international tax provisions, will take effect in fiscal year 2027.
The effective tax rate for fiscal year 2026 was favorably impacted by the impacts of the OBBBA, primarily due to current fiscal year U.S. R&D expenditures no longer being capitalized within GILTI, which the Company has elected to treat as a period cost. The effective tax rates for fiscal years 2025 and 2024 were unfavorably impacted by the TCJA provision that required R&D expenditures incurred in those periods to be capitalized and amortized ratably over five or fifteen years depending on the location in which the research activities are conducted, which resulted in increased GILTI inclusions in each prior period. All periods presented were unfavorably impacted by U.S. tax rules related to refundable tax credits, including R&D expenditure credits available to us in the United Kingdom, that reduce the amount of foreign tax credits available to offset GILTI.
The TCJA also required companies to pay a one-time transition tax on earnings of certain foreign subsidiaries that were previously tax-deferred. We elected to pay the transition tax over the eight-year period provided in the TCJA. As of March 28, 2026, there is no remaining balance of our transition tax obligation, as the final installment was paid in fiscal year 2026.
Cash paid for income taxes (net of refunds) consisted of the following (in thousands):
| | | | | | | | |
| | Fiscal Year Ended |
| | March 28, 2026 |
| U.S. Federal | | $ | 14,381 | |
| U.S. State and Local | | 171 | |
| Foreign: | | |
| United Kingdom | | 34,819 | |
| Other | | 250 | |
| Cash paid for income taxes (net of refunds) | | $ | 49,621 | |
Deferred tax assets and liabilities are recorded for the estimated tax impact of temporary differences between the tax basis and book basis of assets and liabilities. Significant components of our deferred tax assets and liabilities as of March 28, 2026 and March 29, 2025 were as follows (in thousands):
| | | | | | | | | | | | | | |
| | March 28, 2026 | | March 29, 2025 |
| Deferred tax assets: | | | | |
| Accrued expenses and allowances | | $ | 3,622 | | | $ | 3,939 | |
| Net operating loss carryforwards | | 609 | | | 889 | |
| Research and development tax credit carryforwards | | 11,867 | | | 12,024 | |
| Stock-based compensation | | 22,757 | | | 23,099 | |
| Lease liabilities | | 22,563 | | | 23,562 | |
| Capitalized research and development | | 8,482 | | | 10,461 | |
| Depreciation and amortization | | 11,896 | | | 6,823 | |
| Other | | 766 | | | 714 | |
| Total deferred tax assets | | $ | 82,562 | | | $ | 81,511 | |
| Valuation allowance for deferred tax assets | | (12,445) | | | (12,475) | |
| Net deferred tax assets | | $ | 70,117 | | | $ | 69,036 | |
| Deferred tax liabilities: | | | | |
| Right of use asset | | 20,072 | | | 20,302 | |
| Acquisition intangibles | | — | | | 134 | |
| Other | | 221 | | | 450 | |
| Total deferred tax liabilities | | $ | 20,293 | | | $ | 20,886 | |
| Total net deferred tax assets | | $ | 49,824 | | | $ | 48,150 | |
At March 28, 2026, the Company had gross federal net operating loss carryforwards of $0.8 million that are subject to certain limitations under Section 382 of the Internal Revenue Code and expire in fiscal years 2027 through 2031. At March 28, 2026 the Company had gross foreign net operating loss carryforwards of $0.1 million that do not expire and gross state net operating loss carryforwards of $5.6 million that expire in fiscal years 2027 through 2030. In addition, the Company had $12.0 million of state minimum tax and research and development tax credit carryforwards. Certain of these state tax credits will expire in fiscal years 2031 through 2034, and others do not expire.
A valuation allowance is established against a deferred tax asset when it is more likely than not that the deferred tax asset will not be realized. The Company maintains a valuation allowance for certain deferred tax assets, primarily relating to certain state net operating loss and state tax credit carryforwards due to the likelihood that they will expire or go unutilized. Our valuation allowance decreased by $31 thousand in fiscal year 2026, which was the net effect of a gross increase of $225 thousand that affected the effective tax rate and a gross decrease of $256 thousand that was offset by a corresponding reduction in deferred tax assets on the balance sheet. Management believes that the Company’s results from future operations will
generate sufficient taxable income in the appropriate jurisdictions and of the appropriate character such that it is more likely than not that the remaining deferred tax assets will be realized.
At March 28, 2026, unremitted earnings of our foreign subsidiaries that can be distributed without tax consequence, other than withholding taxes that may apply based on the jurisdiction of the subsidiary, are not expected to be indefinitely reinvested. No taxes have been accrued for potential foreign withholding taxes on other foreign earnings as these amounts are not material. We have not provided additional income taxes for other outside basis differences inherent in our foreign entities, as these amounts continue to be indefinitely reinvested in foreign operations. Determining the amount of unrecognized deferred tax liability related to all other outside basis differences in these entities is not practicable at this time.
On July 27, 2015, the U.S. Tax Court issued an opinion in Altera Corp. et al. v. Commissioner which concluded that the regulations relating to the treatment of stock-based compensation expense in intercompany cost-sharing arrangements were invalid. In 2016 the U.S. Internal Revenue Service appealed the decision to the U.S. Court of Appeals for the Ninth Circuit (the "Ninth Circuit"). On July 24, 2018, the Ninth Circuit issued a decision that was subsequently withdrawn and a reconstituted panel conferred on the appeal. On June 7, 2019, the Ninth Circuit reversed the decision of the U.S. Tax Court and upheld the cost-sharing regulations. On February 10, 2020, Altera Corp. filed a Petition for a Writ of Certiorari with the Supreme Court of the United States, which was denied by the Supreme Court on June 22, 2020. Although the issue is now resolved within the Ninth Circuit, the Ninth Circuit's opinion is not binding in other circuits. The potential impact of this issue on the Company, which is not located within the jurisdiction of the Ninth Circuit, is unclear at this time. We will continue to monitor developments related to this issue and the potential impact of those developments on the Company's current and prior fiscal years.
The following table summarizes the changes in the unrecognized tax benefits (in thousands):
| | | | | | | | | | | | | | |
| | March 28, 2026 | | March 29, 2025 |
| Beginning balance | | $ | 32,077 | | | $ | 32,077 | |
| Additions | | — | | | — | |
| | | | |
| Reductions | | — | | | — | |
| Ending balance | | $ | 32,077 | | | $ | 32,077 | |
At March 28, 2026, the Company had gross unrecognized tax benefits of $32.1 million, all of which would impact the effective tax rate if recognized. The Company’s unrecognized tax benefits are classified as "Non-current income taxes" in the consolidated balance sheet. The Company recognizes interest and penalties related to unrecognized tax benefits in the provision for income taxes. During fiscal years 2026 and 2025 we recognized interest expense, net of tax, of approximately $2.7 million and $2.8 million, respectively. The total amount of interest accrued as of March 28, 2026 was $14.6 million.
The Company and its subsidiaries are subject to U.S. federal income tax as well as income tax in multiple state and foreign jurisdictions including the United Kingdom. Fiscal years 2017 through 2019 and 2023 through 2026 remain open to examination by the major taxing jurisdictions in which the Company operates.
The Company's fiscal year 2017, 2018, and 2019 federal income tax returns are under examination by the U.S. Internal Revenue Service ("IRS"). The IRS has proposed adjustments that would increase U.S. taxable income related to transfer pricing matters with respect to our U.S. and U.K. affiliated companies. The final Revenue Agent’s Report asserted additional tax of approximately $168.3 million, excluding interest, and imposed penalties of approximately $63.7 million. The Company does not agree with the IRS's positions and has not accrued an additional liability. In July 2024, the Company entered the administrative dispute process with the IRS Independent Office of Appeals ("IRS Appeals"). The Company continues to vigorously dispute the proposed adjustments, including through ongoing discussions as part of the administrative process with IRS Appeals. If an acceptable outcome cannot be reached with IRS Appeals, the Company is prepared to pursue judicial remedies, which could take a number of years to resolve. Although the final resolution of these matters is uncertain, the Company believes adequate amounts have been reserved in accordance with ASC 740 for any adjustments to the provision for income taxes that may ultimately result. However, the ultimate amount of assessed tax, interest, and penalties, if any, could be material and may have an adverse impact on our financial position, results of operations, and cash flows in future periods. The Company is not under an income tax audit in any other major taxing jurisdiction.