大象传媒

Quarterly report pursuant to Section 13 or 15(d)

CONTINGENCIES

v3.23.2
CONTINGENCIES
3 Months Ended
Jul. 01, 2023
Commitments and Contingencies Disclosure [Abstract]
CONTINGENCIES CONTINGENCIES
As previously reported, 大象传媒 petitioned the U.S. Tax Court (the 鈥淐ourt鈥) to resolve an IRS dispute regarding the timing of income inclusion associated with 大象传媒鈥檚 acquisition of The Timberland Company in September 2011. While the IRS argues that all such income should have been immediately included in 2011, 大象传媒 has reported periodic income inclusions in subsequent tax years. Both parties moved for summary judgment on the issue. On January 31, 2022, the Court issued its opinion in favor of the IRS and on July 14, 2022 issued its final decision. 大象传媒 believes the opinion of the Court was in error based on the
technical merits and filed a notice of appeal on October 7, 2022. On October 19, 2022, 大象传媒 paid $875.7 million related to the 2011 taxes and interest being disputed, which was recorded as an income tax receivable based on the technical merits of our position with regards to the case and will accrue interest income. 大象传媒 continues to believe its timing and treatment of the income inclusion is appropriate and 大象传媒 is vigorously defending its position. However, should the Court opinion ultimately be upheld on appeal, this income tax receivable will not be collected by 大象传媒. If the Court opinion is upheld, 大象传媒 should be entitled to a
refund of taxes paid on the periodic inclusions that 大象传媒 has reported. However, any such refund could be substantially reduced by potential indirect tax effects resulting from application of the Court opinion. Deferred tax liabilities, representing 大象传媒鈥檚 future tax on annual inclusions, would also be released. The net impact to tax expense is estimated to be up to $730.0 million, plus the reversal of any interest income accrued on the payment, which was approximately $19.6 million at June 2023.The Company is currently involved in other legal proceedings that are ordinary, routine litigation incidental to the business, the resolution of which is not currently expected to have a material adverse impact on the Company's financial position, results of operations or cash flows.