
	Year Ended
	January 30, 2021		February 1, 2020		February 2, 2019
Current income tax provision (benefit):
Federal	$	3,210	$	5,223	$	46,519
State	3,439		(1,937)		5,959
Foreign	(12,028)		(4,137)		3,322
Total current income tax provision (benefit)	(5,379)		(851)		55,800
Deferred income tax provision (benefit):
Federal	(14,401)		(125,892)		134,336
State	870		(9,382)		(6,567)
Foreign	(25,960)		(649,884)		(9,122)
Total deferred income tax provision (benefit)	(39,491)		(785,158)		118,647
Total provision (benefit) for income taxes	$	(44,870)	$	(786,009)	$	174,447

The Company consists of a Bermuda parent holding company with various foreign and U.S. subsidiaries. The applicable statutory rate in Bermuda is zero for the Company for fiscal 2021, 2020, and 2019. For purposes of the reconciliation between the provision (benefit) for income taxes at the statutory rate and the effective tax rate, a U.S. statutory tax rate of 21% for fiscal years 2021, 2020 and 2019 is applied as follows:


	Year Ended
	January 30, 2021		February 1, 2020		February 2, 2019

Provision at U.S. statutory rate	$	(67,655)	$	167,660	$	(976)
State taxes, net of federal benefit	327		(9,878)		(9,652)
Difference in U.S. and non-U.S. tax rates	38,118		(181,625)		46,988
Foreign income inclusion in U.S.	861		13,736		167,093
Non-deductible compensation	4,108		6,196		13,215
Intellectual property transaction	—		(762,933)		93,777

Federal research and development credits	(49,315)		(42,604)		(29,503)
Uncertain tax positions	(19,957)		(3,913)		4,238
Change in valuation allowance	49,315		26,971		(110,921)
Other	(672)		381		188
Income tax provision (benefit)	$	(44,870)	$	(786,009)	$	174,447

The income tax benefit for fiscal 2021 is primarily attributable to the pretax losses of the Company’s subsidiaries with income tax rates that differ from the U.S. statutory tax rate, combined with a net reduction of unrecognized tax benefits inclusive of interest and penalties, offset by tax expense attributable to non-deductible compensation. The income tax benefit for fiscal 2020 was primarily the result of the recognition of a $763.0 million tax benefit for the intra-entity transfer of the majority of the Company’s intellectual property to a subsidiary in Singapore. This resulted in the recognition of a deferred tax asset and tax benefit of $659.0 million related to the Singapore tax basis in the intellectual property. In addition, the Company recognized $104.0 million of income tax benefit from the reversal of deferred tax liabilities primarily related to previously acquired intangible assets. The income tax expense for fiscal 2019 was primarily the result of restructurings involving the transfer of certain assets and intellectual property used in the business among various subsidiaries and represented the estimated U.S. tax to be paid currently and in future years on income generated from the intellectual property transfer. The prior period transactions aligned the global economic ownership of the Company's intellectual property rights with its current and future business operations. The Company continues to evaluate potential changes to its legal entity structure in response to guidelines and requirements in various international tax jurisdictions, as well as in response to changes in our operations, and acquisitions and divestitures.


	January 30, 2021		February 1, 2020
Deferred tax assets:
Net operating losses	$	78,253	$	105,925
Federal and California income tax credits	713,799		631,805
Intangible assets	629,290		632,537
Reserves and accruals	69,654		22,719
Share-based compensation	4,798		4,117
Lease liabilities	28,176		32,120
Gross deferred tax assets	1,523,970		1,429,223
Valuation allowance	(749,468)		(676,780)
Total deferred tax assets	774,502		752,443
Deferred tax liabilities:
Intangible assets	(50,557)		(69,771)
Fixed assets	(27,549)		(27,540)
Unremitted earnings of non-U.S. subsidiaries	(20,173)		(21,284)

Right of use assets	(26,158)		(25,290)
Total deferred tax liabilities	(124,437)		(143,885)
Net deferred tax assets (liabilities)	$	650,065	$	608,558

In assessing the realization of deferred tax assets, management considers whether it is more likely than not that some portion or all of the deferred assets will be realized. The ultimate realization of the deferred tax assets is dependent upon the generation of future taxable income during the periods in which those temporary differences become deductible or creditable. The Company weighs all positive and negative evidence including our earnings history, results of recent operations, reversals of deferred tax liabilities, projected future taxable income, and tax planning strategies. As of January 30, 2021, the Company recorded a valuation allowance of $749.5 million which is an increase of $72.7 million from fiscal 2020. The Company provided a full valuation allowance against its federal and state research and development and other tax credits. Based on the available objectively verifiable positive and negative evidence, the Company determined that it is more likely than not that these tax credits and a limited amount of net operating losses will not be realized in the future. The Company also provided a valuation allowance against the deferred tax assets of a portion of its operations in Israel, which has cumulative losses in recent years and is not projecting sufficient future taxable income to realize the benefit of its deferred tax assets, as well as a valuation allowance against Canadian research and development credits. It is also possible that significant negative evidence may become available that causes the Company to conclude that a valuation allowance is needed on certain of its other deferred tax assets, which would adversely affect the Company's income tax provision in the period of such change in judgment.

As of January 30, 2021, the Company had net operating loss carryforwards available to offset future taxable income of approximately $832.6 million, $517.3 million and $815.1 million for U.S. federal, state of California and foreign purposes, respectively. The federal carryforwards will begin to expire in fiscal year 2022, and the California carryforwards will begin to expire in fiscal year 2028, if not utilized before these years. The majority of the Company’s foreign losses carry forward indefinitely. The Company also had federal research and other tax credit carryforwards of approximately $360.3 million which will begin to expire in fiscal 2022. As of January 30, 2021, the Company also had California research tax credit carryforwards of approximately $478.6 million, which can be carried forward indefinitely. The Company also has research and other tax credit carryforwards of approximately $28.8 million in other U.S. states which will begin to expire in fiscal 2022 due to the statutes of limitation.

Utilization of the Company's U.S. federal and state net operating loss and credit carryforwards may be subject to annual limitations due to ownership change provisions by the Internal Revenue Code of 1986, as amended, and similar state provisions. The annual limitation may result in the expiration of net operating losses and credits before utilization. Future changes in the Company's stock ownership, some of which are outside of the Company's control, could result in an ownership change under Section 382 and result in a limitation on US tax attributes. As of January 30, 2021, the Company had approximately $801.1 million and $120.4 million of federal net operating loss and tax credit carryforwards, respectively, in the U.S. subject to an annual limitation. The Company does not expect these limitations to result in any permanent loss of its tax benefits.


	Year Ended
	January 30, 2021		February 1, 2020		February 2, 2019
Unrecognized tax benefits as of the beginning of the period	$	166,828	$	158,323	$	23,252
Increases related to acquired tax positions	—		9,215		131,631
Increases related to prior year tax positions	77,878		1,789		1,836
Decreases related to prior year tax positions	(1,106)		(6,747)		(6,259)
Increases related to current year tax positions	5,603		7,614		11,154

Settlements	(476)		(443)		—
Lapse in the statute of limitations	(8,193)		(4,044)		(3,198)
Foreign exchange (gain) loss	1,616		1,121		(93)
Gross amounts of unrecognized tax benefits as of the end of the period	$	242,150	$	166,828	$	158,323

Included in the balances as of January 30, 2021 is $171.5 million of unrecognized tax benefit that would affect the effective income tax rate if recognized. Also, in the year ended January 30, 2021, the Company increased its uncertain prior year tax positions by $77.9 million which included $75.1 million related to items that had been previously accrued as deferred tax liabilities and are now reflected as reductions to deferred tax assets at January 30, 2021, as a result of a current year change in the Company's assessment of its future income tax filing positions for these items. Finally, $221.7 million, $146.6 million and $135.6 million of the gross unrecognized tax benefits presented in the table above are offset against deferred tax assets in the consolidated balance sheets as of January 30, 2021, February 1, 2020 and February 2, 2019, respectively.

The amounts in the table above do not include the related interest and penalties. The amount of interest and penalties accrued was approximately $4.0 million, $12.4 million, and $15.1 million as of January 30, 2021, February 1, 2020, and February 2, 2019, respectively. The Company’s policy is to recognize these interest and penalties as a component of income tax expense. The consolidated statements of operations for fiscal 2021, 2020, and 2019 included $1.0 million, $1.4 million, and $2.7 million, respectively, of interest and penalties related to the unrecognized tax benefits.

The Company's major tax jurisdictions are the United States, the states of California and Massachusetts, China, India, Israel, and Singapore. The Company is subject to income tax audits by the respective tax authorities in all of the jurisdictions in which it operates. The examination of tax liabilities in each of these jurisdictions requires the interpretation and application of complex and sometimes uncertain tax laws and regulations. As of January 30, 2021, the Company is subject to examination in material jurisdictions including China, India, Israel, Singapore, Germany, and the United States for fiscal years 2001 through 2021.

The Company will continue to review its tax positions and provide for or reverse unrecognized tax benefits as issues arise. During the next 12 months, it is reasonably possible that the amount of unrecognized tax benefits could increase or decrease significantly due to changes in tax law in various jurisdictions, new tax audits and changes in the U.S. dollar as compared to foreign currencies within the next 12 months. Excluding these factors, uncertain tax positions may decrease by $5.4 million from the lapse of the statutes of limitation in various jurisdictions during the next 12 months.

The Singapore Economic Development Board (“EDB”) initially granted a 10-year Pioneer Status in July 1999 to the Company’s Singapore subsidiary. In October 2004, the Company’s subsidiary in Singapore was granted a second incentive known as the Development and Expansion Incentive (“DEI”), and in June 2006, the EDB agreed to extend the Pioneer status for 15 years to June 2014. The Company renegotiated with the Singapore government and in fiscal 2015, they extended the DEI tax incentives to the Company until June 2019. The Company renegotiated again with the Singapore government and during the second quarter of fiscal 2020, they extended the DEI tax incentives until June 2024. In the future, the Company may negotiate a further extension of these incentives. In order to retain these tax benefits in Singapore, the Company must meet certain operating conditions relating to, among other things, certain headcount and investment requirements, as well as maintenance of a regional headquarters function, and certain research and development activities in Singapore. There was no such benefit in fiscal 2021, 2020, and 2019.

Under the Israeli Encouragement law of “approved or benefited enterprise,” Marvell Israel (M.I.S.L) Ltd., is entitled to approved and benefited tax programs that include reduced tax rates and exemption of certain income with respect to its Galileo switches activity, subject to various operating and other conditions. Income from the approved or benefited enterprises, with the exception of capital gains, is eligible up to fiscal 2027. In fiscal 2021, tax savings associated with these tax holidays were approximately $2.1 million, which if paid would impact the Company’s earnings per share by less than $0.01 per share in fiscal 2021. There was no such benefit recognized in fiscal 2020 or fiscal 2019.

The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was enacted into US federal law on March 27, 2020. The CARES Act provided numerous tax provisions and other stimulus measures, including temporary changes regarding the prior and future utilization of net operating losses, temporary changes to the prior and future limitations on interest deductions, and technical corrections from prior tax legislation for tax depreciation of certain qualified improvement property. The Company evaluated the provisions of the CARES Act and concluded that there was no material impact on its financial statements. The tax effects of other related foreign government assistance enacted into law this period are also not material to the Company this period.

The Company’s principal source of liquidity as of January 30, 2021 consisted of approximately $748.5 million of cash and cash equivalents, of which approximately $618.1 million was held by subsidiaries outside of Bermuda. The Company has not recognized a deferred tax liability on $264.2 million of these assets as those amounts are deemed to be indefinitely reinvested. The Company plans to use such amounts to fund various activities outside of Bermuda, including working capital requirements, capital expenditures for expansion, funding of future acquisitions or other financing activities.