## Table

|  |  | Fiscal Year Ended August 31, |  |
|---|---|---|---|
|  | 2019 | 2018 | 2017 |
| Beginning balance | $256,705 | $201,355 | $149,898 |
| Additions for tax positions of prior years | 20,158 | 14,465 | 2,155 |
| Reductions for tax positions of prior years(1) | (106,252) | (21,045) | (12,233) |
| Additions for tax positions related to current year(2) | 35,769 | 81,866 | 77,807 |
| Cash settlements | — | (1,659) | (2,298) |
| Reductions from lapses in statutes of limitations | (2,570) | (7,496) | (10,446) |
| Reductions from settlements with taxing authorities(3) | (35,582) | (5,928) | (6,061) |
| Foreign exchange rate adjustment | (3,845) | (4,853) | 2,533 |
| Ending balance | $164,383 | $256,705 | $201,355 |
| Unrecognized tax benefits that would affect the effective tax rate (if recognized) | $93,237 | $117,455 | $75,223 |



## Text

Unrecognized Tax Benefits


Reconciliation of the unrecognized tax benefits is summarized below (in thousands):


(1) The reductions for tax positions of prior years for the fiscal year ended August 31, 2019 are primarily related to a non-U.S. taxing authority ruling related to certain non-U.S. net operating loss carry forwards, offset with a valuation allowance and the impacts of the Tax Act.


(2) The additions for the fiscal years ended August 31, 2019 and 2018 are primarily related to the impacts of the Tax Act and taxation of certain intercompany transactions. The additions for the fiscal year ended August 31, 2017 are primarily related to certain non-U.S. net operating loss carry forwards, previously offset with a valuation allowance, that can no longer be recognized due to an internal restructuring.


(3) The reductions from settlements with taxing authorities for the fiscal year ended August 31, 2019 are primarily related to the settlement of a U.S. audit.


The Company recognizes interest and penalties related to unrecognized tax benefits in income tax expense. The Company’s accrued interest and penalties were approximately $18.9 million and $20.4 million as of August 31, 2019 and 2018, respectively. The Company recognized interest and penalties of approximately $(1.5) million, $(6.7) million and $5.2 million during the fiscal years ended August 31, 2019, 2018 and 2017, respectively.


It is reasonably possible that the August 31, 2019 unrecognized tax benefits could decrease during the next 12 months by $5.8 million, primarily related to a state settlement.


The Company is no longer subject to U.S. federal tax examinations for fiscal years before August 31, 2015. In major non-U.S. and state jurisdictions, the Company is no longer subject to income tax examinations for fiscal years before August 31, 2009.


The Internal Revenue Service (“IRS”) completed its field examination of the Company’s tax returns for fiscal years 2009 through 2011 and issued a Revenue Agent’s Report (“RAR”) on May 27, 2015, which was updated on June 22, 2016. The IRS completed its field examination of the Company’s tax returns for fiscal years 2012 through 2014 and issued an RAR on April 19, 2017. The proposed adjustments in the RAR from both examination periods relate primarily to U.S. taxation of certain intercompany transactions. On May 8, 2019, the tax return audits for fiscal years 2009 through 2014 were effectively settled when the Company agreed to the IRS Office of Appeals’ Form 870-AD (Offer to Waive Restrictions on Assessment and Collection of Tax Deficiency and to Accept Overassessment) adjustments, which were substantially lower than the initial RAR proposed adjustments. The settlement did not have a material effect on the Company’s financial position, results of operations, or cash flows and no additional tax liabilities were recorded.