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Income Taxes
12 Months Ended
Dec. 31, 2019
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
Income taxes have been provided for based upon the tax laws and rates in countries in which our operations are conducted and income is earned. The Company received an assurance from the Bermuda Minister of Finance that it would be exempted from local income, withholding and capital gains taxes until March 2035. Consequently, the provision for income taxes relates to income earned by certain subsidiaries of the Company which are located in, or earn income in, jurisdictions that impose income taxes, primarily the United States and Ireland.
The sources of income from continuing operations before income taxes and earnings of unconsolidated equity method investment for the years ended December 31, 2019, 2018 and 2017 were as follows:
 
Year Ended December 31,
 
2019
 
2018
 
2017
U.S. operations
$
9,085

 
$
8,104

 
$
2,801

Non-U.S. operations
166,055

 
253,543

 
143,504

Income from continuing operations before income taxes and earnings of unconsolidated equity method investment
$
175,140

 
$
261,647

 
$
146,305





The components of the income tax provision from continuing operations for the years ended December 31, 2019, 2018 and 2017 consisted of the following:
 
Year Ended December 31,
 
2019
 
2018
 
2017
Current:
 
 
 
 
 
United States:
 
 
 
 
 
Federal
$
782

 
$
2,446

 
$
6,503

State
437

 
(136
)
 
1,913

Non-U.S.
1,225

 
3,828

 
6,574

Current income tax provision
2,444

 
6,138

 
14,990

Deferred:
 
 
 
 
 
United States:
 
 
 
 
 
Federal
7,205

 
2,901

 
(5,474
)
State
2,018

 
759

 
(1,161
)
Non-U.S.
11,000

 
(4,156
)
 
(2,313
)
Deferred income tax provision (benefit)
20,223

 
(496
)
 
(8,948
)
Total
$
22,667

 
$
5,642

 
$
6,042


Significant components of the Company’s deferred tax assets and liabilities at December 31, 2019, 2018 and 2017 consisted of the following:
 
Year Ended December 31,
 
2019
 
2018
 
2017
Deferred tax assets:
 
 
 
 
 
Non-cash share-based payments
$
614

 
$
2,182

 
$
1,899

Net operating loss carry forwards
69,806

 
48,660

 
22,804

Other
72,732

 
1,795

 
1,272

Total deferred tax assets
143,152

 
52,637

 
25,975

Deferred tax liabilities:
 
 
 
 
 
Accelerated depreciation
(136,268
)
 
(95,107
)
 
(62,379
)
Other
(70,551
)
 
(338
)
 
354

Total deferred tax liabilities
(206,819
)
 
(95,445
)
 
(62,025
)
 
 
 
 
 
 
Net deferred tax liabilities
$
(63,667
)
 
$
(42,808
)
 
$
(36,050
)

The Company had $69,332 of net operating loss (“NOL”) carry forwards available at December 31, 2019 to offset future taxable income subject to U.S. graduated tax rates. If not utilized, $47,850 of these carry forwards will expire by 2039, with $21,482 of these carry forwards having no expiration date. The Company also had NOL carry forwards of $488,600 with no expiration date to offset future Irish and Mauritius taxable income. Deferred tax assets and liabilities are included in Other assets and Accounts payable and accrued liabilities, respectively, in the accompanying Consolidated Balance Sheets.
We do not expect to incur income taxes on future distributions of undistributed earnings of non-U.S. subsidiaries and accordingly, no deferred income taxes have been provided for the distributions of such earnings. As of December 31, 2019 we have elected to permanently reinvest our accumulated undistributed U.S. earnings of $27,970. Accordingly, no U.S. withholding taxes have been provided. Withholding tax of $1,398 would be due if such earnings were remitted.
Our aircraft-owning subsidiaries that are recognized as corporations for U.S. tax purposes are primarily non-U.S. corporations. These subsidiaries generally earn income from sources outside the United States and typically are not subject to U.S. federal, state or local income taxes. The aircraft owning subsidiaries resident in Ireland, Mauritius and the U.S. are subject to tax in those respective jurisdictions.
We have a U.S.-based subsidiary which provides management services to our subsidiaries and is subject to U.S. federal, state and local income taxes. We also have Ireland and Singapore based subsidiaries which provide management services to our non-U.S. subsidiaries and are subject to tax in those respective jurisdictions.
Differences between statutory income tax rates and our effective income tax rates applied to pre-tax income from continuing operations at December 31, 2019, 2018 and 2017 consisted of the following:
 
Year Ended December 31,
 
2019
 
2018
 
2017
Notional U.S. federal income tax expense at the statutory rate:
$
36,779

 
$
54,946

 
$
51,207

U.S. state and local income tax, net
1,549

 
525

 
168

Non-U.S. operations:
 
 
 
 
 
Bermuda
(16,950
)
 
(41,064
)
 
(21,517
)
Ireland
(99
)
 
(2,567
)
 
(2,348
)
Singapore
(28
)
 
(3,232
)
 
(15,839
)
Other low tax jurisdictions
(2,504
)
 
(3,246
)
 
(5,581
)
Non-deductible expenses in the U.S.
3,581

 
157

 
(236
)
Other
339

 
123

 
188

 
 
 
 
 
 
Provision for income taxes
$
22,667

 
$
5,642

 
$
6,042


The Company recognizes the tax benefit from an uncertain tax position only if it is more likely than not that the tax position will be sustained on examination by the taxing authorities. We did not have any unrecognized tax benefits.
We conduct business globally and, as a result, the Company and its subsidiaries or branches are subject to foreign, U.S. federal and various state and local income taxes, as well as withholding taxes. In the normal course of business the Company is subject to examination by taxing authorities throughout the world, including such major jurisdictions as Ireland and the United States.
Our policy is that we will recognize interest and penalties accrued on any unrecognized tax benefits as a component of income tax expense. We did not accrue interest or penalties associated with any unrecognized tax benefits, nor was any interest expense or penalty recognized during the year.