INCOME TAXES

Income before provision for income taxes shown below was based on the geographic location to which such income was attributed as follows:



	For the Years Ended December 31,
	2014			2013		2012
Income before income tax expense:
Domestic	$	(7,229	)	$	7,001	$	9,291
Foreign	94,182			69,769		56,572
Total	$	86,953		$	76,770	$	65,863



	For the Years Ended December 31,
	2014			2013			2012
Income tax expense (benefit) consists of:
Current
Federal	$	7,741		$	6,150		$	6,881
State	338			310			319
Foreign	12,504			8,275			7,969
Deferred
Federal	(3,979		)	(668		)	(625		)
State	(43		)	14			24
Foreign	751			695			(3,189		)
Total	$	17,312		$	14,776		$	11,379

Deferred tax assets and liabilities are provided for the effects of temporary differences between the tax basis of an asset and liability and its reported amount in the consolidated balance sheets. These temporary differences result in taxable or deductible amounts in future years.

The components of the Company’s deferred tax assets and liabilities were as follows:



	December 31, 2014			December 31, 2013
Deferred tax assets:
Fixed assets	$	181		$	732
Intangible assets	3,789			4,532
Accrued expenses	1,282			3,488
Net operating loss carryforward	844			—
Deferred revenue	4,328			2,050
Stock-based compensation	6,994			407
Valuation allowance	(149		)	—
Restricted stock options	2			1,336
Other assets	30			680
Deferred tax assets	17,301			13,225
Deferred tax liabilities:
Fixed assets	800			804
Accrued revenue and expenses	635			846
Deferred inter-company gain	405			405
Equity compensation	7,013			1,593
Other liabilities	24			254
Deferred tax liability	8,877			3,902
Net deferred tax asset	$	8,424		$	9,323

At December 31, 2014, the Company had current and non-current deferred tax assets of $2,496 and $11,094, respectively, and current and non-current tax liabilities of $603 and $4,563, respectively. At December 31, 2013, the Company had current and non-current deferred tax assets of $5,392 and $4,557, respectively, and current and non-current tax liabilities of $275 and $351, respectively.

At December 31, 2014, the Company has a net operating loss in China and Singapore related to the acquisition of Jointech. This net operating loss will be utilized prior to its expiration. No provision has been made for U.S. or non-U.S. income taxes on the undistributed earnings of subsidiaries or for unrecognized deferred tax liabilities for temporary differences related to basis differences in investments in subsidiaries, as such earnings are expected to be permanently reinvested, the investments are essentially permanent in duration, or the Company has concluded that no additional tax liability will arise as a result of the distribution of such earnings. As of December 31, 2014, certain subsidiaries had approximately $340.5 million of undistributed earnings that we intend to permanently reinvest. A liability could arise if our intention to permanently reinvest such earnings were to change and amounts are distributed by such subsidiaries or if such subsidiaries are ultimately disposed. It is not practicable to estimate the additional income taxes related to permanently reinvested earnings or the basis differences related to investments in subsidiaries.

The provision for income taxes differs from the amount of income tax determined by applying the applicable US statutory federal income tax rate to pretax income as follows:



	For the Years Ended December 31,
	2014			2013			2012
Statutory federal tax	$	29,564		$	26,102		$	22,393
Increase/ (decrease) in taxes resulting from:
State taxes, net of federal benefit	311			368			280
Provision adjustment for current year uncertain tax position	(1,220		)	—			—
Effect of permanent differences	8,589			2,524			2,177
Stock-based compensation	3,782			1,948			1,165
Rate differential between U.S. and foreign	(24,772		)	(17,279		)	(14,472		)
Change in foreign tax rate	754			(59		)	148
Change in valuation allowance	149			489			(489		)
Other	155			683			177
Provision for income taxes	$	17,312		$	14,776		$	11,379

On September 22, 2005, the president of Belarus signed the decree “On the High-Technologies Park” (the “Decree”). The Decree is aimed at boosting the country’s high-technology sector. The Decree stipulates that member technology companies have a 100% exemption from Belarusian income tax of 18% effective July 1, 2006. The Decree is in effect for a period of 15 years from July 1, 2006.

The Company’s subsidiary in Hungary benefits from a tax credit of 10% of annual qualified salaries, taken over a 4-year period, for up to 70% of the total tax due for that period. The Company has been able to take the full 70% credit for 2008 - 2014. The Hungarian tax authorities repealed the tax credit beginning with 2012. However, credits earned in the years prior to 2012, will be allowed to be used through 2014. The Company has utilized the 70% limit through 2014.

The aggregate dollar benefits derived from these tax holidays approximated $16.8 million, $9.7 million and $8.5 million for the years ended December 31, 2014, 2013 and 2012, respectively. The benefit the tax holiday had on diluted net income per share approximated $0.34, $0.20 and $0.19 for the years ended December 31, 2014, 2013 and 2012, respectively.

The liability for unrecognized tax benefits is included in income tax liability within the consolidated balance sheets at December 31, 2014 and 2013. At December 31, 2014 and 2013, the total amount of gross unrecognized tax benefits (excluding the federal benefit received from state tax positions) was $200 and $1,271, respectively, (excluding penalties and interest of $12 and $189, respectively). Of this total, $212 and $1,328, respectively, (net of the federal benefit on state tax issues) represents the amount of unrecognized tax benefits that, if recognized, would favorably affect the effective tax rate in future periods.

The Company’s policy is to recognize interest and penalties related to uncertain tax positions as a component of its provision for income taxes. The total amount of accrued interest and penalties resulting from such unrecognized tax benefits was $12, $189 and $125 at December 31, 2014, 2013 and 2012, respectively.

The beginning to ending reconciliation of the gross unrecognized tax benefits were as follows:



	For the Years Ended December 31,
	2014			2013		2012
Gross Balance at January 1	$	1,271		$	1,271	$	1,271
Increases in tax positions in current year	—			—		—
Increases in tax positions in prior year	—			—		—
Decreases due to settlement	(1,071		)	—		—
Balance at December 31	$	200		$	1,271	$	1,271

There were no tax positions for which it was reasonably possible that unrecognized tax benefits will significantly increase or decrease within 12 months of the reporting date.

The Company files income tax returns in the United States and in various states, local and foreign jurisdictions. The Company’s significant tax jurisdictions are the U.S. Federal, Pennsylvania, Canada, Russia, Denmark, Germany, Ukraine, the United Kingdom, Hungary, Switzerland and Kazakhstan. As a result of 2014 acquisitions, the Company has an additional filing responsibility in Singapore, Hong Kong and China. The tax years subsequent to 2010 remain open to examination by the Internal Revenue Service. Generally, the tax years subsequent to 2010 remain open to examination by various state and local taxing authorities and various foreign taxing authorities.