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Income Taxes
12 Months Ended
Dec. 31, 2016
Income Tax Disclosure [Abstract]  
Income Taxes

16.Income Taxes

Income tax expense (benefit) is composed of the following (in thousands):

 

 

Year Ended December 31,

 

 

 

2016

 

 

2015

 

 

2014

 

Current:

 

 

 

 

 

 

 

 

 

 

 

 

Federal

 

$

(30,301

)

 

$

52,578

 

 

$

1,358

 

State

 

 

5,623

 

 

 

15,275

 

 

 

4,035

 

Total current (benefit) expense

 

 

(24,678

)

 

 

67,853

 

 

 

5,393

 

Deferred:

 

 

 

 

 

 

 

 

 

 

 

 

Federal

 

 

31,122

 

 

 

(46,364

)

 

 

(9,636

)

State

 

 

989

 

 

 

(11,752

)

 

 

(2,827

)

Total deferred expense (benefit)

 

 

32,111

 

 

 

(58,116

)

 

 

(12,463

)

Income tax expense (benefit)

 

$

7,433

 

 

$

9,737

 

 

$

(7,070

)

 

The Company operates in only one federal jurisdiction, the United States. The following table presents a reconciliation of the income tax benefit computed at the statutory federal rate and the Company’s income tax expense (benefit) (in thousands):

 

 

 

Year Ended December 31,

 

 

 

2016

 

 

2015

 

 

2014

 

Income tax benefit—computed as 35% of pretax loss

 

$

(82,286

)

 

$

(85,235

)

 

$

(60,546

)

Effect of non-controlling interests and redeemable

   non-controlling interests

 

 

91,183

 

 

 

93,221

 

 

 

47,962

 

Goodwill impairment

 

 

12,810

 

 

 

—

 

 

 

—

 

Amortization of prepaid tax asset

 

 

11,750

 

 

 

6,661

 

 

 

2,199

 

Effect of nondeductible expenses

 

 

6,942

 

 

 

1,232

 

 

 

6,617

 

State and local income tax expenses (net of federal benefit)

 

 

4,298

 

 

 

2,289

 

 

 

616

 

Effect of domestic production activities deduction

 

 

(473

)

 

 

(4,699

)

 

 

—

 

Effect of tax credits

 

 

(36,328

)

 

 

(4,106

)

 

 

(3,939

)

Other

 

 

(463

)

 

 

374

 

 

 

21

 

Income tax expense (benefit)

 

$

7,433

 

 

$

9,737

 

 

$

(7,070

)

Deferred income taxes reflect the impact of temporary differences between assets and liabilities for financial reporting purposes and the amounts recognized for income tax reporting purposes, net operating loss carryforwards and other tax credits measured by applying currently enacted tax laws. The significant components of the Company’s deferred tax assets and liabilities were as follows (in thousands):  

 

 

December 31,

 

 

 

2016

 

 

2015

 

Deferred tax assets:

 

 

 

 

 

 

 

 

Accruals and reserves

 

$

8,523

 

 

$

4,582

 

Stock-based compensation

 

 

7,791

 

 

 

9,068

 

Tax credits

 

 

1,744

 

 

 

—

 

Transaction costs

 

 

—

 

 

 

4,216

 

Other

 

 

351

 

 

 

395

 

Gross deferred tax assets

 

 

18,409

 

 

 

18,261

 

Valuation allowance

 

 

(204

)

 

 

(212

)

Net deferred tax assets

 

 

18,205

 

 

 

18,049

 

Deferred tax liabilities:

 

 

 

 

 

 

 

 

Investment in solar funds

 

 

(368,536

)

 

 

(220,803

)

Depreciation and amortization

 

 

(38,116

)

 

 

(13,004

)

Interest rate swaps

 

 

(5,732

)

 

 

—

 

Accruals and reserves

 

 

(1,039

)

 

 

(275

)

Gross deferred tax liabilities

 

 

(413,423

)

 

 

(234,082

)

Net deferred tax liabilities

 

$

(395,218

)

 

$

(216,033

)

 

The Company sells solar energy systems under long-term customer contracts to substantially all of the investment funds for income tax purposes. As the investment funds are consolidated by the Company, the gain on the sale of the solar energy systems is not recognized in the consolidated financial statements. However, this gain is recognized for tax reporting purposes. Since these transactions are intercompany sales for GAAP purposes, any tax expense incurred related to these intercompany sales is deferred and amortized over the estimated useful life of the underlying solar energy systems, which has been estimated to be 30 years. Accordingly, the Company has recorded a prepaid tax asset, net of $419.5 million and $277.5 million as of December 31, 2016 and 2015.

The future reversal of deferred tax liabilities is expected to produce a sufficient source of future taxable income of the necessary character and in the necessary periods and jurisdictions to support the realization of the deferred tax assets. As such, no valuation allowance is required except for as noted below.

The Company had net operating loss carryforwards of approximately $1.1 million and $1.3 million related to state (the “NOLs”), available to offset future taxable income as of December 31, 2016 and 2015. The NOLs expire in varying amounts from 2029 through 2034 for state tax purposes if unused. As of December 31, 2016 and 2015, the Company recognized a valuation allowance of $0.2 million for the existing state NOLs and other existing state tax attributes due to state-imposed limitations on their utilization.

The Company reported federal business tax credits, primarily composed of federal investment tax credits, of $36.3 million and $4.1 million for the years ended December 31, 2016 and 2015. The Company accounts for its federal business tax credits as a reduction of income tax expense in the year in which the credits arise. As of December 31, 2016, the Company had $33.2 million of federal income tax refunds receivable which were recorded in prepaid expenses and other current assets. The Company did not have any federal income tax refunds receivable as of December 31, 2015.

Uncertain Tax Positions

As of December 31, 2016 and 2015, the Company had no unrecognized tax benefits. There were no interest and penalties accrued for any uncertain tax positions as of December 31, 2016 and 2015. The Company does not have any tax positions for which it is reasonably possible the total amount of gross unrecognized benefits will increase or decrease within 12 months of the year ended December 31, 2016. The Company is subject to taxation and files income tax returns in the United States and various state and local jurisdictions. Substantially all of the Company’s federal, state and local income tax returns since inception are still subject to audit.