XML 31 R15.htm IDEA: XBRL DOCUMENT v3.10.0.1
Income Taxes
12 Months Ended
Dec. 31, 2018
Income Tax Disclosure [Abstract]  
Income Taxes

7.    INCOME TAXES

The following table presents the U.S. and non‑U.S. components of income (loss) before income tax expense:

 

 

 

For the Year Ended December 31,

 

 

 

2018

 

 

2017

 

 

2016

 

U.S.

 

$

 

237,920

 

 

$

 

279,038

 

 

$

 

172,401

 

Non-U.S.

 

 

 

532

 

 

 

 

71,313

 

 

 

 

(5,727

)

Income (loss) before income taxes

 

$

 

238,452

 

 

$

 

350,351

 

 

$

 

166,674

 

 

The current and deferred components of the income tax provision for the years ended December 31, 2018, 2017, and 2016 are as follows:

 

 

 

For the Year Ended December 31,

 

 

 

2018

 

 

2017

 

 

2016

 

Current income taxes:

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Federal

 

$

 

15,023

 

 

$

 

19,923

 

 

$

 

22,178

 

State and Local

 

 

 

7,218

 

 

 

 

4,556

 

 

 

 

5,361

 

Foreign

 

 

 

1,393

 

 

 

 

7,651

 

 

 

 

(1,716

)

 

 

$

 

23,634

 

 

$

 

32,130

 

 

$

 

25,823

 

Deferred income taxes:

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Federal

 

$

 

5,221

 

 

$

 

192,102

 

 

$

 

(848

)

State and Local

 

 

 

1,087

 

 

 

 

1,538

 

 

 

 

(207

)

Foreign

 

 

 

506

 

 

 

 

(1,943

)

 

 

 

41

 

Total

 

$

 

30,448

 

 

$

 

223,827

 

 

$

 

24,809

 

 

The total provision for income taxes differs from the amount which would be computed by applying the appropriate statutory rate to income before income taxes as follows:

 

 

 

For the Year Ended December 31,

 

 

 

 

2018

 

 

2017

 

 

2016

 

 

Reconciliation of federal statutory tax rates

 

 

 

 

 

 

 

 

 

 

 

 

 

U.S. statutory tax rate

 

 

21.0

 

%

 

35.0

 

%

 

35.0

 

%

Increase (decrease) due to state and local taxes

 

 

4.0

 

%

2.7

 

%

2.3

 

%

Rate benefit as a U.S. limited partnership/flow through

 

 

-6.1

 

%

-10.1

 

%

-21.8

 

%

Estimated re-measurement impact primarily related to the Tax Act

 

 

0.0

 

%

51.7

 

%

 

0.0

 

%

Other income from reduction of amount due pursuant to tax receivable agreement in connection with the Tax Act

 

 

0.0

 

%

-14.6

 

%

 

0.0

 

%

Excess tax benefit from equity compensation delivery

 

-5.7

 

%

-1.7

 

%

 

0.0

 

%

Foreign taxes

 

0.4

 

%

0.7

 

%

-0.9

 

%

Other

 

-0.8

 

%

0.2

 

%

0.3

 

%

Effective income tax rate

 

 

12.8

 

%

 

63.9

 

%

 

14.9

 

%

 

Deferred income taxes reflect the net effect of temporary differences between the tax basis of an asset or liability and its reported amount in the Company’s consolidated statements of financial condition. These temporary differences result in taxable or deductible amounts in future years. The significant components of deferred tax assets and liabilities included on the Company’s consolidated statements of financial condition are as follows:

 

 

 

For the Year Ended December 31,

 

 

 

2018

 

 

2017

 

Net operating loss

 

$

 

8,397

 

 

$

 

7,685

 

Step-up in tax basis in Group LP assets

 

 

 

356,069

 

 

 

 

208,799

 

Deferred Compensation

 

 

 

45,875

 

 

 

 

28,043

 

Accrued expenses and other

 

 

 

(468

)

 

 

 

292

 

 

 

 

 

409,873

 

 

 

 

244,819

 

Valuation allowance on NOL and other

 

 

 

(7,014

)

 

 

 

(10,819

)

Net deferred tax asset

 

$

 

402,859

 

 

$

 

234,000

 

 

The Company recorded an increase in the net deferred tax asset of $168,859 for the twelve months ended December 31, 2018, which was primarily attributable to the step-up in tax basis in Group LP assets resulting from the redemption of Class A partnership units in connection with the Company’s follow-on offerings in March and August 2018. Approximately $171,506 of this deferred tax asset is attributable to exchanges by certain partners of Group LP who are party to the tax receivable agreement. Pursuant to this agreement, 85% (or $145,780) of the tax benefits associated with this portion of the deferred tax asset are payable to such exchanging partners over the next 15 years and recorded as amount due pursuant to tax receivable agreement in the consolidated statements of financial condition. The remaining tax benefit is allocable to the Company and is recorded in additional paid-in-capital. The Company also recorded an increase in the deferred tax asset related to deferred equity compensation, which was principally offset by the vesting and delivery of equity awards during 2018.  

On December 22, 2017, the U.S. enacted comprehensive tax legislation commonly referred to as the Tax Cuts and Jobs Act (“Tax Act”). The Tax Act made broad and complex changes to the U.S. tax code including, but not limited to, reducing the U.S. federal corporate tax rate from 35 percent to 21 percent, effective January 1, 2018. The SEC staff issued SAB 118, which provides guidance on accounting for the tax effects of the Tax Act. In accordance with SAB 118, a company must reflect the income tax effects of those aspects of the Tax Act for which the accounting under ASC 740 is complete or a reasonable estimate if such accounting is incomplete. The Company recorded a provisional amount related to its analysis of the impact of the Tax Act in its consolidated statements of financial condition for the year ended December 31, 2017. The Company has completed its analysis of the income tax effects of the Tax Act in accordance with SAB 118 and there has been no additional impact recorded.  

As of December 31, 2018, the Company had accumulated net foreign operating loss carryforwards related to its international operations of approximately $31,566 for which it has recorded a deferred tax asset of $8,397. Approximately $28,714 of the operating losses (or $7,658 of the deferred tax asset) has an indefinite life and $2,852 of the operating losses (or $739 of the deferred tax asset) will expire on dates between 2019 and 2026.

The Company’s operations are comprised of entities that are organized as limited liability companies and limited partnerships. For U.S. federal income tax purposes, taxes related to income earned by these entities represent obligations of their interest holders. In connection with the Company’s reorganization and IPO, the Company became subject to U.S. corporate federal, state and local income tax on its allocable share of results of operations from Group LP.

The Company is subject to taxation in certain U.S., state, local, and foreign jurisdictions. As of December 31, 2018, the Company’s tax years for 2017, 2016, 2015, and 2014 are generally subject to examination by the tax authorities. As of December 31, 2018, the Company does not expect any material changes in its tax provision related to any outstanding current examinations. Developments with respect to such examinations are monitored on an ongoing basis and adjustments to tax liabilities are made as appropriate.

The Company has no unrecognized tax benefits for the periods ended December 31, 2018, 2017 and 2016.