INCOME TAXES (Tables)

12 Months Ended

Dec. 31, 2023

The major components of the income tax recovery are:


Years ended December 31,	2023		2022
Current income tax:
Current taxes	$	8,450	$	8,079
Current taxes referring to previous periods	(1,854)		(819)
Withholding taxes and other	110		120
	$	6,706	$	7,380
Deferred income tax:
Origination and reversal of temporary differences	$	(25,660)	$	(71,195)
Impact of changes in tax rates	—		(17,330)



Withholding taxes on profits of subsidiaries	86		—
Deferred tax expense arising from the write-down, or reversal of a previous write-down, of a deferred tax asset	8,877		16,771
Other	502		709
	$	(16,195)	$	(71,045)
Income tax recovery	$	(9,489)	$	(63,665)

The effective income tax rate reported in the combined statements of net income varies from the Canadian statutory rate for the following reasons:




Years ended December 31,	2023		2022
Income before income taxes	$	129,007	$	92,157
Expected income taxes at the Canadian statutory tax rate of 26.5% (2022 - 26.5%)	$	34,187	$	24,422
Income distributed and taxable to unitholders	(51,921)		(92,252)
Net foreign rate differentials	(811)		9,145
Net change in provisions for uncertain tax positions	(548)		719
Net permanent differences	507		(6,151)
Net effect of change in tax rates	—		(17,330)
Non-recognition of deferred tax assets	8,877		16,770

Withholding taxes and other	220		1,012
Income tax recovery	$	(9,489)	$	(63,665)

Deferred tax assets and liabilities consist of temporary differences related to the following:


As at December 31,	2023		2022
Deferred tax assets:

Loss carryforwards	$	602	$	629
Other	37		—
Deferred tax assets	$	639	$	629
Deferred tax liabilities:
Investment properties	$	540,304	$	562,578
Withholding tax on undistributed subsidiary profits	86		—
Other	(4,839)		(5,187)
Deferred tax liabilities	$	535,551	$	557,391

Changes in the net deferred tax liabilities consist of the following:


Years ended December 31,	2023		2022
Balance, beginning of year	$	556,762	$	600,215
Deferred tax recovery recognized in net income	(16,195)		(71,045)
Foreign currency translation of deferred tax balances	(5,655)		27,592
Net deferred tax liabilities, end of year	$	534,912	$	556,762

A reconciliation of the beginning and ending amounts of unrecognized tax benefits is as follows:


As at December 31,	2023		2022
Unrecognized tax benefits balance, beginning of year	$	10,279	$	10,470
Decreases for tax positions of prior years	(1,815)		(1,692)
Increases for tax positions of current year	1,244		1,452
Foreign currency impact	87		49
Unrecognized tax benefits balance, end of year	$	9,795	$	10,279

As at December 31, 2023, the following tax years remained subject to examination: