Income Taxes

As a result of the Reorganization, the operating business entities of the Company were restructured and a portion of the Company’s income is subject to U.S. federal, state, local and foreign income taxes and is taxed at the prevailing corporate tax rates. Taxes Payable as of December 31, 2015 and 2014 were $20,886 and $2,515, respectively.

The following table presents the U.S. and non-U.S. components of Income before income tax expense:



	For the Years Ended December 31,
	2015		2014		2013
U.S.	$	81,157	$	124,747	$	89,821
Non-U.S.	38,736		30,883		28,735
Income before Income Tax Expense (a)	$	119,893	$	155,630	$	118,556


(a)	From continuing operations, net of Noncontrolling Interest from continuing operations.

The components of the provision for income taxes from continuing operations reflected on the Consolidated Statements of Operations for the years ended December 31, 2015, 2014 and 2013 consist of:



	For the Years Ended December 31,
	2015			2014			2013
Current:
Federal	$	56,064		$	33,814		$	24,607
Foreign	9,798			10,513			11,982
State and Local	14,795			10,114			7,541
Total Current	80,657			54,441			44,130
Deferred:
Federal	(1,196		)	15,104			5,992
Foreign	659			(3,080		)	4,733
State and Local	(3,090		)	2,291			8,834
Total Deferred	(3,627		)	14,315			19,559
Total	$	77,030		$	68,756		$	63,689

A reconciliation between the federal statutory income tax rate from continuing operations and the Company’s effective income tax rate for the years ended December 31, 2015, 2014 and 2013 is as follows:



	For the Years Ended December 31,
	2015		2014		2013
Reconciliation of Federal Statutory Tax Rates:
U.S. Statutory Tax Rate	35.0	%	35.0	%	35.0	%
Increase Due to State and Local Taxes	7.0	%	6.0	%	5.3	%
Rate Benefits as a Limited Liability Company/Flow Through	(5.9	)%	(4.2	)%	(7.0	)%
Foreign Taxes	1.5	%	0.4	%	3.2	%
Non-Deductible Expenses (1)	19.9	%	1.1	%	3.4	%
Valuation Allowances	—	%	0.9	%	—	%
Write Down of Deferred Tax Asset	—	%	—	%	6.8	%
Other Adjustments	(0.3	)%	(0.2	)%	(0.7	)%
Effective Income Tax Rate	57.2	%	39.0	%	46.0	%


(1)	Primarily related to non-deductible share-based compensation expense.

Undistributed earnings of certain foreign subsidiaries totaled approximately $5,378 as of December 31, 2015. Deferred taxes have not been provided on the undistributed earnings of certain foreign subsidiaries, as the Company considers these amounts to be indefinitely reinvested to finance international growth and expansion. As of December 31, 2015, unrecognized net deferred tax liability attributable to those reinvested earnings would have aggregated approximately $1,598. In the event that such amounts were ever remitted, loaned to the Company, or if the stock in the foreign subsidiary was sold, these earnings could become subject to U.S. Federal tax and an income tax provision, if any, would be recognized at that time.

Deferred income taxes are provided for the effects of temporary differences between the tax basis of an asset or liability and its reported amount in the Consolidated Statements of Financial Condition. These temporary differences result in taxable or deductible amounts in future years. Details of the Company’s deferred tax assets and liabilities as of December 31, 2015 and 2014 were as follows:



	December 31,
	2015			2014
Current Deferred Tax Assets (1):
Step up in tax basis due to the exchange of LP Units for Class A Shares	$	—		$	13,096
Total Current Deferred Tax Asset	$	—		$	13,096
Long-term Deferred Tax Assets:
Depreciation and Amortization	$	29,498		$	25,978
Compensation and Benefits	35,120			32,535
Step up in tax basis due to the exchange of LP Units for Class A Shares	215,827			208,970
Other	38,349			27,419
Total Long-term Deferred Tax Assets	$	318,794		$	294,902
Long-term Deferred Tax Liabilities:
Goodwill, Intangible Assets and Other	$	19,169		$	27,396
Total Long-term Deferred Tax Liabilities	$	19,169		$	27,396
Net Long-term Deferred Tax Assets Before Valuation Allowance	$	299,625		$	267,506
Valuation Allowance	(1,510		)	(1,605		)
Net Long-term Deferred Tax Assets	$	298,115		$	265,901


(1)	The Company adopted ASU 2015-17 prospectively as of December 31, 2015 and changed its presentation of deferred tax assets and liabilities such that the Company classifies all deferred tax assets and liabilities as noncurrent. See Note 2 for further information.

The increase in net deferred tax assets from December 31, 2014 to December 31, 2015 was partially attributable to an increase in the tax basis of the tangible and intangible assets of Evercore LP, which resulted from the 2015 LP Unit exchanges. During 2015, the LP holders exchanged 314 Class A LP Units for Class A Shares, which resulted in an increase in the tax basis of the tangible and intangible assets of Evercore LP. Further, the exchange of 277 of such Class A LP Units triggered an additional liability under the tax receivable agreement that was entered into in 2006 between the Company and the LP Unit holders. The agreement provides for a payment to the LP Unit holders of 85% of the cash tax savings (if any), resulting from the increased tax benefits from the exchange and for the Company to retain 15% of such benefits. Accordingly, Deferred Tax Assets – Non-Current, Amounts Due Pursuant to Tax Receivable Agreements and Additional Paid-In-Capital increased $7,812, $6,641 and $1,172, respectively, on the Company’s Consolidated Statement of Financial Condition as of December 31, 2015. See Note 14 for further discussion. This amount was offset by a $13,701 reduction in deferred tax assets related to the 2015 amortization of the tax basis in the tangible and intangible assets of Evercore LP.

Additionally, the increase in net deferred tax assets from December 31, 2014 to December 31, 2015 was also attributable to an increase of $3,520 related to the depreciation of fixed assets and amortization of intangible assets.

There was a net decrease of $8,227 in the deferred tax liabilities from December 31, 2014 to December 31, 2015, primarily related to the goodwill impairment in the Investment Management segment.

The Company reported an increase in deferred tax assets of $455 associated with changes in Unrealized Gain (Loss) on Marketable Securities and an increase of $8,492 associated with changes in Foreign Currency Translation Adjustment Gain (Loss), in Accumulated Other Comprehensive Income (Loss) for the year ended December 31, 2015. The Company reported an increase in deferred tax assets of $1,072 associated with changes in Unrealized Gain (Loss) on Marketable Securities and an increase of $5,129 associated with changes in Foreign Currency Translation Adjustment Gain (Loss), in Accumulated Other Comprehensive Income (Loss) for the year ended December 31, 2014.

The Company's affiliates generated approximately $5,054 of NYC unincorporated business tax credit carryforwards, which are set to expire in 2017. Management has weighed both the positive and negative evidence and determined that it was appropriate to establish a valuation allowance of $1,510, on the amount of credits that are not expected to be realized.

A reconciliation of the changes in tax positions for the years ended December 31, 2015, 2014 and 2013 is as follows:



	December 31,
	2015		2014			2013
Beginning unrecognized tax benefit	$	—	$	624		$	98
Additions for tax positions of prior years	—		276			526
Reductions for tax positions of prior years	—		—			—
Lapse of Statute of Limitations	—		(98		)	—
Decrease due to settlement with Taxing Authority	—		(802		)	—
Ending unrecognized tax benefit	$	—	$	—		$	624

The Company classifies interest relating to tax matters and tax penalties as a component of income tax expense in its Consolidated Statements of Operations. Related to the unrecognized tax benefits, the Company did not recognize any interest and penalties during the year ended December 31, 2015. The Company recognized $191 of interest and penalties during the year ended December 31, 2014, prior to the settlement of the NYC UBT audit. The Company has $229 accrued for the payment of interest and penalties as of December 31, 2014, prior to the settlement of the audit.

The Company is subject to taxation in the U.S. and various state, local and foreign jurisdictions. The Company’s tax years for 2011 to present are subject to examination by the taxing authorities. The Company is currently under examination by New York City for tax years 2011 through 2013. With a few exceptions, the Company is no longer subject to U.S. federal, state, local or foreign examinations by taxing authorities for years before 2012.