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Income Taxes
6 Months Ended
Jun. 30, 2020
Income Taxes  
Income Taxes

11.         Income Taxes

As an exempted company incorporated under the laws of Bermuda, the Company is principally subject to taxation in Bermuda. Under the current laws of Bermuda, tax on a company’s income is assessed at a zero percent tax rate. As a result, the Company has not recorded any income tax benefits from losses incurred in Bermuda during each reporting period, and no net operating loss carryforwards will be available to the Company for those losses. The Company’s wholly owned U.S. subsidiaries, Kiniksa US and Primatope, are subject to federal and state income taxes in the United States. The Company’s wholly owned subsidiary Kiniksa UK, and its wholly owned subsidiaries, Kiniksa Germany, Kiniksa France, and Kiniksa Switzerland are subject to taxation in their respective countries. Certain of the Company’s subsidiaries, primarily Kiniksa US, operate under cost-plus arrangements.

The income tax rate for the three and six months ended June 30, 2020 varied from the Bermuda statutory rate of zero primarily due to income subject to United States taxation under the Kiniksa US cost-plus arrangement with the Company, net of the deduction for FDII, U.S. federal and state research tax credits and the recognition of a valuation allowance against deferred tax assets. Income tax expense for the three and six months ended June 30, 2020 was $5,875 and $3,696, respectively, and includes discrete tax expense primarily related to the recognition of a valuation allowance against deferred tax assets, partially offset by the tax benefits from share-based compensation taxable events. The Company’s income tax rate for the three and six months ended June 30, 2019 was not materially different than the Bermuda statutory rate.

Management examines all positive and negative evidence to estimate whether sufficient future taxable income in the U.S. will be generated to permit the use of existing deferred tax assets. As a result of significant cumulative tax benefits associated with share-based compensation taxable events recognized in the six months ended June 30, 2020, the Company has significant negative evidence in the form of cumulative losses and does not believe that they are at a more likely than not position for utilizing the deferred tax assets in the United States. As such, the Company recorded a valuation allowance against its U.S. deferred tax asset as of June 30, 2020. There are no material deferred tax assets in the other jurisdictions.