INCOME TAXES

PBF Energy

For periods following PBF Energy’s IPO, PBF Energy is required to file federal and applicable state corporate income tax returns and recognizes income taxes on its pre-tax income, which to date has consisted solely of its share of PBF LLC’s pre-tax income (approximately 40.9% prior to the January 2014 secondary offering, 56.4% prior to the March 2014 secondary offering and approximately 71.9% subsequent to the March 2014 secondary offering). PBF LLC is organized as a limited liability company which is treated as a "flow-through" entity for federal income tax purposes and therefore is not subject to income taxes. As a result, the PBF Energy condensed consolidated financial statements do not reflect any benefit or provision for income taxes on the pre-tax income or loss attributable to the noncontrolling interest in PBF LLC.

The income tax provision in the PBF Energy condensed consolidated financial statements of operations consists of the following:



	Three Months Ended March 31, 2014		Three Months Ended March 31, 2013
Current tax benefit	$	16,719	$	—
Deferred tax expense	32,960		7,444
Total tax expense	$	49,679	$	7,444

The difference between the Company’s income tax expense and the income tax provision computed by applying the United States statutory rate and the difference between the Company’s effective income tax rate and the United States statutory rate are reconciled below:



	Three Months Ended March 31, 2014					Three Months Ended March 31, 2013
Provision at Federal statutory rate	$	44,493		35.0	%	$	6,598	35.0	%
Increase (decrease) attributable to flow-through of certain tax adjustments:
State income taxes (net federal income tax)	6,623			5.2	%	819		4.3	%
Non deductible/nontaxable items	178			0.1	%	18		0.1	%
Other	(1,615		)	(1.3	)%	9		0.1	%
Total	$	49,679		39.0	%	$	7,444	39.5	%

PBF Energy has determined there are no material uncertain tax positions as of March 31, 2014.

PBF Holding

PBF Holding is a limited liability company treated as a "flow-through" entity for income tax purposes. Accordingly there is no benefit or provision for federal or state income tax in the accompanying PBF Holding financial statements.