XML 39 R23.htm IDEA: XBRL DOCUMENT v3.20.2
INCOME TAXES
9 Months Ended
Sep. 30, 2020
Income Tax Disclosure [Abstract]  
Income Taxes
INCOME TAXES
Deferred income taxes reflect the net effect of temporary differences between the tax basis of an asset or liability and its reported amount on the Company’s condensed consolidated balance sheets. These temporary differences result in taxable or deductible amounts in future years. The Company's net deferred tax assets were $0.3 million and $0.2 million as of September 30, 2020 and December 31, 2019, respectively. The Company's deferred tax assets consists primarily of temporary differences relating to certain accrued expenses, stock-based compensation, unrealized losses and a tax benefit relating to tax goodwill. The Company's deferred tax asset balance as of September 30, 2020 and December 31, 2019 is presented net of a valuation allowance of $5.2 million and $6.0 million, respectively. Deferred tax liabilities as of September 30, 2020 and December 31, 2019 were $0.8 million and $0.6 million, respectively.
The quarterly provision for income taxes is determined based on the Company’s estimated annual effective tax rate adjusted by the amount of tax attributable to infrequent or unusual items that are recognized on a discrete basis in the income tax provision in the period in which they occur. The Company’s effective tax rate includes a rate benefit attributable to the fact that the Company’s subsidiaries operate as limited liability companies, which are not subject to federal or state income tax. Accordingly, a portion of the Company’s earnings attributable to non-controlling interests are not subject to corporate level taxes. However, a portion of the Company's subsidiaries' income is subject to New York City’s unincorporated business tax. For the three and nine months ended September 30, 2020 and 2019, the Company was only subject to federal, state and city corporate income taxes on its pre-tax income (loss) attributable to Medley Management Inc. Due to potential changes in the Company’s period-to-period results, fluctuations in the Company’s effective tax rate and respective tax provisions or benefits may occur.
On March 27, 2020, the “Coronavirus Aid, Relief and Economic Security (CARES) Act” was signed into law. The Act includes provisions relating to refundable payroll tax credits, deferment of the employer portion of certain payroll taxes, net operating loss carryback periods, alternative minimum tax credit refunds, modifications to the net interest deduction limitations and technical corrections to tax depreciation methods for qualified improvement property.  
The Company’s effective tax rate was 15.9% and 10.0% for the three months ended September 30, 2020 and 2019, respectively and 9.4% and 5.6% for the nine months ended September 30, 2020 and 2019, respectively. During the three and nine months ended September 30, 2020, the Company's effective tax rate was impacted by a favorable current income tax benefit of $1.6 million primarily due to provisions of the CARES Act, allowing for the carryback of net operating losses which are currently being projected for 2020. Also impacting the effective tax rate is a full valuation allowance being provided by the Company on its projected annual net deferred tax assets as well as losses allocated to non-controlling interests which are not subject to subject to federal, state and city corporate income taxes. During the three and nine months ended September 30, 2019, the Company's effective tax rate was impacted primarily by losses allocated to non-controlling interests which are not subject to subject to federal, state and city corporate income taxes, as well as discrete items associated with the vesting of restricted LLC Units and payment of dividend equivalent payments on restricted stock units.
Interest expense and penalties related to income tax matters are recognized as a component of the provision for income taxes and were not significant during the three and nine months ended September 30, 2020 and 2019. As of and during the three and nine months ended September 30, 2020 and 2019, there were no uncertain tax positions taken that were not more likely than not to be sustained. The primary jurisdictions in which the Company operates in are the United States, New York State, New York City, and California.