INCOME TAXES

The components of loss before income taxes, after adjusting the loss for non-controlling interests, are as follows:



	Three months ended March 31,						Six months ended March 31,
	2020			2019			2020			2019
United States	$	701,000		$	(1,298,000	)	$	554,000		$	(2,422,000	)
Canada	(2,215,000		)	(862,000		)	(2,484,000		)	(4,443,000		)
	$	(1,514,000	)	$	(2,160,000	)	$	(1,930,000	)	$	(6,865,000	)

The components of the income tax benefit are as follows:



	Three months ended March 31,					Six months ended March 31,
	2020		2019			2020			2019
Current	$	—	$	(1,000	)	$	7,000		$	(34,000	)
Deferred	—		(34,000		)	(9,000		)	(106,000		)
	$	—	$	(35,000	)	$	(2,000	)	$	(140,000	)

Consolidated taxes do not bear a customary relationship to pretax results due primarily to the fact that the Company is taxed separately in Canada based on Canadian source operations and in the U.S. based on consolidated operations, and essentially all deferred tax assets, net of relevant offsetting deferred tax liabilities, are not estimated to have a future benefit as tax credits or deductions. Income from our non-controlling interest in the Kukio Resort Land Development Partnerships is treated as non-unitary for state of Hawaii unitary filing purposes, thus unitary Hawaii losses provide limited sheltering of such non-unitary income.

On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was signed into law to provide economic relief to businesses that were negatively impacted by the COVID-19 pandemic. Key tax provisions of the CARES Act currently impacting the Company include the modification of rules related to alternative minimum tax (“AMT”) credits and net operating losses (“NOL”). Other provisions of the CARES Act are currently inapplicable to the Company and/or do not impact the Company’s U.S. federal current and deferred income taxes.

Under previous legislation, 50% of the total AMT credit carryover was refundable upon the filing of the Company's U.S. federal income tax return for the year ended September 30, 2019 and was reclassified to current taxes receivable as of September 30, 2019. The CARES Act provides for an election, which the Company has made, to take the entire refundable credit in the Company’s U.S. federal income tax return for the year ended September 30, 2019. As such, the Company reclassified the remaining 50% from non‑current income taxes receivable to current income taxes receivable as of March 31, 2020 as a result of CARES Act.

Under previous legislation, the utilization of NOLs generated in tax years beginning after December 31, 2017, which was the Company's fiscal year ended September 30, 2019, was restricted to 80% of taxable income. The CARES Act suspended this restriction through the 2020 tax year (the Company’s fiscal year ending September 30, 2021). This limitation will be reinstated effective for tax years beginning on or after January 1, 2021.