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Income and Mining Taxes
12 Months Ended
Dec. 31, 2015
Income Tax Disclosure [Abstract]  
INCOME AND MINING TAXES
INCOME AND MINING TAXES
The components of Income (loss) before income taxes are below:
 
Year ended December 31,
In thousands
2015
 
2014
 
2013
United States
$
(43,924
)
 
$
(213,883
)
 
$
(242,562
)
Foreign
(349,522
)
 
(1,401,245
)
 
(566,117
)
Total
$
(393,446
)
 
$
(1,615,128
)
 
$
(808,679
)

The components of the consolidated Income and mining tax (expense) benefit from continuing operations are below:
 
Year ended December 31,
In thousands
2015
 
2014
 
2013
Current:
 

 
 

 
 

United States
$
49

 
$
904

 
$
4

United States — State mining taxes
(4,305
)
 
(879
)
 
(714
)
United States — Foreign withholding tax

 
(6,250
)
 
397

Argentina
715

 
(71
)
 
(137
)
Australia
130

 

 
(914
)
Mexico
(476
)
 
(10,122
)
 
(9,046
)
Bolivia
(5,154
)
 
(4,008
)
 
(6,716
)
Canada
(516
)
 
(145
)
 
(1,936
)
Deferred:
 
 
 
 
 
Argentina
(1,197
)
 
24,478

 
8,062

Australia
3,223

 
(401
)
 
(2
)
Bolivia

 
22,122

 
(4,222
)
Canada
2,875

 
2,662

 

Mexico
27,189

 
394,221

 
94,851

United States
1,778

 
5,743

 
78,489

United States — State mining taxes
1,952

 

 

Income tax (expense) benefit
$
26,263

 
$
428,254

 
$
158,116


A reconciliation of the Company’s effective tax rate with the federal statutory tax rate for the periods indicated is below:
 
Year ended December 31,
In thousands
2015
 
2014
 
2013
Income and mining tax benefit (expense) at statutory rate
$
137,706

 
$
565,295

 
$
283,038

State tax provision from continuing operations
(2,075
)
 
20,253

 
2,245

Change in valuation allowance
(101,027
)
 
(151,191
)
 
(106,802
)
Non-deductible imputed interest

 

 
(214
)
Uncertain tax positions
(1,947
)
 
(4,425
)
 
(5,209
)
U.S. and foreign non-deductible expenses
1,365

 
(4,892
)
 
(2,383
)
Mineral interest related
(19,310
)
 

 

Foreign exchange rates
22,350

 
23,672

 
13,937

Foreign inflation and indexing
1,117

 
3,765

 
2,937

Foreign tax rate differences
(15,980
)
 
(63,930
)
 
(24,108
)
Foreign withholding and other taxes
8,140

 
82,884

 
(100,331
)
Foreign tax credits and other, net
(4,076
)
 
(43,177
)
 
13,153

Mexico permanent reinvestment assertion

 

 
81,853

Income and mining tax benefit (expense)
$
26,263

 
$
428,254

 
$
158,116


At December 31, 2015 and 2014, the significant components of the Company’s deferred tax assets and liabilities are below:
 
Year ended December 31,
In thousands
2015
 
2014
Deferred tax liabilities:
 

 
 

Mexican mining tax
$
15,451

 
$
8,065

Foreign subsidiaries — unremitted earnings
12,999

 
45,249

Inventory
2,353

 
3,135

Royalty and other long-term debt
1,648

 

 
$
32,451

 
$
56,449

Deferred tax assets:
 

 
 

Net operating loss carryforwards
203,958

 
153,701

Mineral properties
34,966

 
46,006

Property, plant, and equipment
6,980

 
38,091

Royalty and other long-term debt

 
5,863

Capital loss carryforwards
3,938

 
35,251

Asset retirement obligation
21,480

 
21,586

Unrealized foreign currency loss and other
8,424

 
8,213

Accrued expenses
17,905

 
9,365

Tax credit carryforwards
26,439

 
56,322

 
324,090

 
374,398

Valuation allowance
(436,829
)
 
(391,510
)
 
(112,739
)
 
(17,112
)
Net deferred tax liabilities
$
145,190

 
$
73,561


The Company reviews the measurement of its deferred tax assets at each balance sheet date. All available evidence, both positive and negative, is considered in determining whether, based upon the weight of the evidence, it is more likely than not that some portion or all of the deferred tax asset will not be realized. Based upon this analysis, the Company has recorded valuation allowances as follows:
 
Year ended December 31,
In thousands
2015
 
2014
U.S. 
$
292,677

 
$
305,534

Argentina
8,376

 
21,520

Canada
1,718

 
2,009

Bolivia
45,177

 
15,948

Mexico
63,373

 
14,816

New Zealand
25,508

 
28,710

Other

 
2,973

 
$
436,829

 
$
391,510



The Company has the following tax attribute carryforwards at December 31, 2015, by jurisdiction:
In thousands
U.S.
 
Argentina
 
Bolivia
 
Canada
 
Mexico
 
New Zealand
 
Other
 
Total
Regular net operating losses
320,511

 
12,210

 
55,019

 
2,182

 
108,191

 
91,096

 
68

 
589,277

Alternative minimum tax net operating losses
187,376

 

 

 

 

 

 

 
187,376

Capital losses
11,195

 

 

 

 

 

 

 
11,195

Alternative minimum tax credits
3,173

 

 

 

 

 

 

 
3,173

Foreign tax credits
19,898

 

 

 

 

 

 

 
19,898



The U.S. net operating losses expire from 2019 through 2035 and the Canada net operating losses will expire from 2029 through 2035. The Mexico net operating losses expire from 2017 to 2035, while the remaining net operating losses from the foreign jurisdictions have an indefinite carryforward period. The majority of the U.S. capital losses expired in 2015. Alternative minimum tax credits do not expire and foreign tax credits expire if unused beginning in 2019.

The Company intends to indefinitely reinvest earnings from certain foreign operations. For the years 2015 and 2014, the Company had no unremitted earnings from these specific foreign operations.
A reconciliation of the beginning and ending amount related to unrecognized tax benefits is below (in thousands):
Unrecognized tax benefits at January 1, 2014
$
15,471

Gross increase to current period tax positions
1,856

Gross increase to prior period tax positions
524

Reductions in unrecognized tax benefits resulting from a lapse of the applicable statute of limitations
(1,767
)
Unrecognized tax benefits at December 31, 2014
$
16,084

Gross increase to current period tax positions
1,030

Gross increase to prior period tax positions
810

Reductions in unrecognized tax benefits resulting from a lapse of the applicable statute of limitations

Unrecognized tax benefits at December 31, 2015
$
17,924


At December 31, 2015, 2014, and 2013, $17.9 million, $16.1 million, and $14.3 million, respectively, of these gross unrecognized benefits would, if recognized, decrease the Company's effective tax rate.

The Company operates in numerous countries around the world and is subject to, and pays annual income taxes under, the various income tax regimes in the countries in which it operates. The Company has historically filed, and continues to file, all required income tax returns and paid the taxes reasonably determined to be due. The tax rules and regulations in many countries are highly complex and subject to interpretation. From time to time, the Company is subject to a review of its historic income tax filings and, in connection with such reviews, disputes can arise with the taxing authorities over the interpretation or application of certain rules to the Company’s business conducted within the country involved.

The Company files income tax returns in various U.S. federal and state jurisdictions, in all identified foreign jurisdictions, and various others. The statute of limitations remains open from 2012 for the US federal jurisdiction and from 2008 for certain other foreign jurisdictions. During 2014, the U.S. Internal Revenue Service concluded its examination of the Company's 2009, 2010, and 2011 tax years. As a result of statutes of limitations that will begin to expire within the next 12 months in various jurisdictions and possible settlement of audit-related issues with taxing authorities in various jurisdictions with respect to which none of these issues are individually significant, the Company believes that it is reasonably possible that the total amount of its unrecognized income tax liability will decrease between $0.5 million and $1.0 million in the next 12 months.
The Company classifies interest and penalties associated with uncertain tax positions as a component of income tax expense and recognized interest and penalties of $9.2 million, $6.9 million, and $4.1 million at December 31, 2015, 2014, and 2013, respectively.