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INCOME AND MINING TAXES
6 Months Ended
Jun. 30, 2018
INCOME AND MINING TAXES.  
INCOME AND MINING TAXES

NOTE 7   INCOME AND MINING TAXES

 

The Company’s income tax expense differs from the amount computed by applying the U.S. federal and state statutory corporate income tax rate of 21% and 35%, for the six months ended June 30, 2018 and 2017, respectively, to income before taxes primarily as a result of valuation allowances being applied to losses, and changes in deferred tax liabilities associated with mineral property interests. The deferred tax liability is impacted by fluctuations in the foreign exchange rate between the Argentina peso and U.S. dollar.

 

The Tax Cuts and Jobs Act (the “Act”) was enacted on December 22, 2017. The Act reduces the US federal corporate tax rate from 35% to 21%, requires companies to pay a one-time transition tax on earnings of certain foreign subsidiaries that were previously tax deferred and creates new taxes on certain foreign sourced earnings. The Company is applying the guidance in SAB 118 when accounting for the enactment date effects of the Act. At June 30, 2018, the Company has not completed the accounting for the tax effects of enactment of the Act; however, in certain cases, the Company has made a reasonable estimate of the effects on the existing deferred tax balances and the one-time transition tax.

 

During the six months ended June 30, 2018, the Company has not made any adjustments to the provisional amounts recorded as of December 31, 2017. The Company will continue to refine its calculations as additional analysis is completed. Estimates may also be affected as a more thorough understanding of the tax law is developed. These changes could be material to income tax expense.

 

The Act subjects a US shareholder to tax on global intangible low-taxed income (“GILTI”) earned by certain foreign subsidiaries. The FASB Staff Q&A, Topic 740, No. 5, Accounting for Global Intangible Low-Taxed Income, states that an entity can make an accounting policy election to either recognize deferred taxes for temporary basis differences expected to reverse as GILTI in future years or provide for the tax expense related to GILTI in the year the tax is incurred as a period expense only. Given the complexity of the GILTI provisions, the Company is still evaluating the effects of the GILTI provisions and have not yet determined which accounting policy will be adopted. At June 30, 2018, because the Company is still evaluating the GILTI provisions and future taxable income subject to GILTI, the Company has performed the GILTI calculation for the current year only, and has not provided additional GILTI on deferred items.

 

For the three and six months ended June 30, 2018, the Company recorded a deferred income tax recovery of $2.1 million and $3.3 million respectively (June 30, 2017 – expense of $0.2 million and recovery of $2.5 million, respectively) as a result of the increased exploration spending on Los Azules, giving rise to a deferred tax benefit partially offset by the devaluation of the Argentina Peso along with the amortization of the flow-through premium.  These recoveries were partially offset by the recognition of a mining tax liability in relation to the Black Fox mine.