Qualcomm 2014 Annual Report Download - page 74

QUALCOMM Incorporated
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
The Company considers the operating earnings of certain non-United States subsidiaries to be indefinitely reinvested outside the United
States based on the Company’s plans for use and/or investment outside the United States and the Company’s belief that its sources of cash and
liquidity in the United States will be sufficient to meet future domestic cash needs. The Company has not recorded a deferred tax liability of
approximately $9.1 billion related to the United States federal and state income taxes and foreign withholding taxes on approximately $25.7
billion of undistributed earnings of certain non-United States subsidiaries indefinitely reinvested outside the United States. Should the Company
decide to no longer indefinitely reinvest such earnings outside the United States, the Company would have to adjust the income tax provision in
the period management makes such determination.
The Company files income tax returns in the United States federal jurisdiction and various state and foreign jurisdictions. The Company is
currently a participant in the Internal Revenue Service (IRS) Compliance Assurance Process, whereby the IRS and the Company endeavor to
agree on the treatment of all tax issues prior to the tax return being filed. The IRS completed its examination of the Company’s tax return for
fiscal 2013 and issued a no change letter in October 2014, resulting in no change to the income tax provision. The Company is no longer subject
to United States federal income tax examinations for years prior to fiscal 2014. The Company is subject to examination by the California
Franchise Tax Board for fiscal years after 2008. The Company is also subject to income taxes in other taxing jurisdictions in the United States
and around the world, many of which are open to tax examinations for periods after fiscal 2000. The Company does not expect the impact of any
future state or foreign audits to be material.
The Company had deferred tax assets and deferred tax liabilities as follows (in millions):
At September 28, 2014 , the Company had unused federal net operating loss carryforwards of $137 million expiring from 2021 through
2033 , unused state net operating loss carryforwards of $1.3 billion expiring from 2015 through 2034 , and unused foreign net operating loss
carryforwards of $42 million , which expire from 2019 through 2024 . At September 28, 2014 , the Company had unused tax credits of $31
million in foreign jurisdictions, which begin to expire in 2015 . The Company does not expect its federal net operating loss carryforwards and its
state income tax credits to expire unused.
F- 18
September 28,
2014
September 29,
2013
Unearned revenues
$
1,189
$
1,305
Accrued liabilities and reserves
529
305
Share-based compensation
404
497
Unrealized losses on marketable securities
370
293
Unused net operating losses
120
91
Other
127
149
Total gross deferred tax assets
2,739
2,640
Valuation allowance
(60
)
(51
)
Total net deferred tax assets
2,679
2,589
Unrealized gains on marketable securities
(484
)
(536
)
Intangible assets
(315
)
(265
)
Property, plant and equipment
(104
)
(129
)
Other
(31
)
(27
)
Total deferred tax liabilities
(934
)
(957
)
Net deferred tax assets
$
1,745
$
1,632
Reported as:
Current deferred tax assets
$
577
$
573
Non-current deferred tax assets
1,174
1,059
Non-current deferred tax assets held for sale (1)
—
2
Non-current deferred tax liabilities (1)
(6
)
(2
)
$
1,745
$
1,632
(1)
Non
-current deferred tax assets held for sale and non-current deferred tax liabilities were included in other assets and other liabilities, respectively, in the
consolidated balance sheets.