Note 18. Income taxes

Loss before the income tax benefit consists of the following;


	2019		2018
U.S.	$	(108,644)	$	(19,369)
Foreign		(126,421)		1,171
Total loss before income tax provision	$	(235,065)	$	(18,198)

The Company files income tax returns in the US federal jurisdiction and various state and foreign jurisdictions. The applicable statutory tax rates vary from none (zero) to 34%. However, because the Company and its subsidiaries have incurred annual corporate income tax losses since their inception, management has determined that it is more likely than not that the Company will not realize the benefits of its US and foreign net deferred tax assets. Therefore, in all jurisdictions where the Company has a net deferred tax asset, the Company has recorded a full valuation allowance to reduce the net carrying amount of the deferred tax assets to zero. The Company’s 2019 income tax benefit of $8.4 million relates to $8.7 million of benefit associated with the net losses in certain foreign jurisdictions offset by current taxes of $0.3 million in other foreign jurisdictions with taxable income.

Income tax (benefit) expense is summarized as follows:


	December 31,		December 31,
	2019		2018
Current:
Federal	$	—	$	—
State		—		—
Foreign		316		81
		316		81
Deferred:
Federal		—		—
State		—		—
Foreign		(8,611)		(255)
		(8,611)		(255)
Income tax (benefit) expense	$	(8,295)	$	(174)

The following is a reconciliation of the provision for income taxes at the U.S. federal statutory rate (21%) to the foreign income tax rate for the years ended:


	December 31,		December 31,
	2019		2018
Tax expense at statutory rate federal	21	%	21	%
Foreign income tax rate difference	1	%	—
Transaction costs	—		(7)	%
Compensation	—		(6)	%
GILTI	—		(1)	%
Non-operating gain on stock acquisition	—		8	%
Goodwill Impairment	(11)	%	—
Change in valuation allowance	(7)	%	(15)	%
Other	—		1	%
	4	%	1	%

The tax effects of temporary differences that gave rise to significant portions of deferred tax assets and liabilities are as follows:


	2019		2018
Deferred tax attributable to:
Net operating losses	$	55,859	$	31,928
Share-based compensation expense		666		302
Accrued liabilities and allowances		1,287		257
Fixed Assets		188		—
ROU lease liability		288		—
Other		69		66
Less: valuation allowance		(55,561)		(29,812)
Total deferred tax assets		2,796		2,741

Deferred tax liabilities attributable to:
Intangible assets		(1,976)		(10,003)
ROU Asset		(194)		—
Deferred revenue		(626)		(1,124)
Total deferred tax liabilities		(2,796)		(11,127)
Net deferred tax liabilities	$	—	$	(8,386)

As of December 31, 2019 and 2018, the Company had no unrecognized tax benefits and no related interest and penalties for the years then ended.

As of December 31, 2019, and 2018, the Company had net operating losses carryforwards of approximately $258 million and $150 million, respectively. Any net deferred tax assets in a jurisdiction have been offset by a full valuation allowance in both 2019 and 2018 due to the uncertainty of realizing any tax benefit for such losses. Releases of the valuation allowances in the future, if any, will be recognized through earnings.

Section 382 of the Internal Revenue Code limits the use of net operating loss and tax credit carry forwards in certain situations where changes occur in the stock ownership of a company. In the event the Company has a change in ownership, utilization of the carry forward could be limited.

In the ordinary course of business, the Company is subject to tax examinations in the jurisdictions in which it files tax returns. The Company’s statute of limitations for assessment is three years for federal and three to four years for state purposes. The federal net operating loss carry forwards remain open for adjustment until the net operating losses are fully utilized. The Company’s statute of limitations is four to six years in the major foreign jurisdictions in which the Company files.

The Company files income tax returns in the US federal jurisdiction and various state and foreign jurisdictions. As of December 31, 2019 and 2018, the Company did not have any liabilities for uncertain tax positions.