Table:
|  |  | Year Ended June 30, |  |
| --- | --- | --- | --- |
|  | 2019 | 2018 | 2017 |
| Expected statutory rate | 26.5% | 26.5% | 26.5% |
| Expected provision for income taxes | $116,752 | $102,323 | $66,131 |
| Effect of foreign tax rate differences | (1,344) | 2,352 | 8,647 |
| Change in valuation allowance | (5,045) | 1,779 | 520 |
| Amortization of deferred charges | — | 4,242 | 6,298 |
| Effect of permanent differences | (577) | 4,332 | 3,673 |
| Effect of changes in unrecognized tax benefits | 31,992 | 5,543 | 14,427 |
| Effect of withholding taxes | 2,097 | 7,927 | 3,845 |
| Difference in tax filings from provision | (250) | 1,321 | (7,836) |
| Effect of U.S. tax reform | — | 19,037 | — |
| Effect of tax credits for research and development | (13,550) | (3,875) | (2,643) |
| Effect of accrual for undistributed earnings | (13,112) | (1,154) | 5,613 |
| Effect of Base Erosion and Anti-Abuse Tax (BEAT) | 16,030 | — | — |
| Other Items | 5,473 | (1) | 1,075 |
| Impact of internal reorganization of subsidiaries | 16,471 | — | (876,114) |
|  | 154,937 | $143,826 | $(776,364) |
Paragraphs:
A reconciliation of the combined Canadian federal and provincial income tax rate with our effective income tax rate is as follows:
In Fiscal 2019, 2018 and 2017, respectively, substantially all the tax rate differential for international jurisdictions was driven by earnings in the United States.
The effective tax rate decreased to a provision of 35.2% for the year ended June 30, 2019, compared to 37.2% for the year ended June 30, 2018. The increase in tax expense of $11.1 million was primarily due to the increase in net income taxed at foreign rates of $10.7 million, an increase of $26.4 million in reserves for unrecognized tax benefits, an increase of $16.1 million arising on the introduction of BEAT in Fiscal 2019, and an increase of $16.3 million relating to the tax impact of internal reorganizations of subsidiaries, partially offset by a the reversal of accruals for undistributed United States earnings of $14.8 million, the Fiscal 2018 impact of United States tax reform of $19.0 million which did not recur in Fiscal 2019, an increase in tax credits for research and development of $9.7 million, an increase of $6.8 million in the release of valuation allowance, a decrease of $5.8 million in the impact of withholding taxes in Fiscal 2019. The remainder of the difference was due to normal course movements and non-material items.
In July 2016, we implemented a reorganization of our subsidiaries worldwide with the view to continuing to enhance operational and administrative efficiencies through further consolidated ownership, management, and development of our intellectual property (IP) in Canada, continuing to reduce the number of entities in our group and working towards our objective of having a single operating legal entity in each jurisdiction. A significant tax benefit of $876.1 million, associated primarily with the recognition of a net deferred tax asset arising from the entry of the IP into Canada, was recognized in the first quarter of Fiscal 2017. For more information relating to this, please refer to our Annual Report on Form 10-K for the year ended June 30, 2017.
As of June 30, 2019, we have approximately $242.3 million of domestic non-capital loss carryforwards. In addition, we have $387.6 million of foreign non-capital loss carryforwards of which $53.8 million have no expiry date. The remainder of the domestic and foreign losses expires between 2020 and 2039. In addition, investment tax credits of $58.6 million will expire between 2020 and 2039.
Question:
What is the average annual Effect of foreign tax rate differences? 
Answer: (-1344+2352+8647)/3 = 3218.33