Income Taxes (Notes) |
6 Months Ended |
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Mar. 29, 2020 | |
| Income Tax Disclosure [Abstract] | |
| Income Taxes |
Note 3. Income Taxes
We estimate our annual effective income tax rate to be 12% for fiscal 2020, which is lower than the U.S. federal statutory rate, primarily due to a significant portion of our income qualifying for preferential treatment as foreign-derived intangible income (FDII) at a 13% effective tax rate and due to benefits from our research and development tax credit. The effective tax rate of 22% for the second quarter of fiscal 2020 was higher than the estimated annual effective tax rate of 12% primarily due to $28 million of discrete net tax charges recorded in the second quarter of fiscal 2020, principally related to foreign currency losses on a noncurrent receivable related to our refund claim of Korean withholding tax.
The United States Treasury Department has issued proposed regulations on several provisions of the 2017 Tax Cuts and Jobs Act, including FDII and interest expense deduction limitations, which may be finalized in the next several months. When finalized, these proposed regulations may adversely affect our provision for income taxes, results of operations and/or cash flows.
Unrecognized tax benefits were $1.8 billion and $1.7 billion at March 29, 2020 and September 29, 2019, respectively, and primarily relate to our refund claim of Korean withholding tax. If successful, the refund will result in a corresponding reduction in U.S. foreign tax credits. We expect that the total amount of unrecognized tax benefits at March 29, 2020 will increase in the next 12 months as licensees in Korea continue to withhold taxes on future payments due under their licensing agreements at a rate higher than we believe is owed; such increase is not expected to have a significant impact on our income tax provision.
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