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Note 3 - Income Taxes
6 Months Ended
Sep. 30, 2017
Notes to Financial Statements  
Income Tax Disclosure [Text Block]
3.
Income Taxes
 
Income taxes have been provided using the asset and liability method. Deferred tax assets and liabilities are recognized for the future tax consequences attributable to differences between the financial statement carrying amounts of existing assets and liabilities and their respective tax bases. Deferred tax assets and liabilities are measured using enacted tax laws and rates expected to apply to taxable income in the years in which those temporary differences are expected to be recovered or settled. The effect of a change in tax rates on deferred tax assets and liabilities is recognized in income in the period that includes the enactment date.
 
During the
six
-month period ended
September 30, 2017,
the Company recorded
$655,000
in income tax expe
nse at an effective rate of
27.7%.
The Company records income taxes using an estimated annual effective tax rate for interim reporting. The individually largest factor contributing to the difference between the federal statutory rate of
34%
and the Company’s effective tax rate for the
six
-month period ended
September 30, 2017
was the change in valuation allowance against Delphax’s pretax activity in the period. Additionally, the estimated annual effective tax rate differs from the U. S. federal statutory rate due to the benefit for the Section
831
(b) income exclusion for SAIC, the benefit for the federal domestic production activities deduction, the increase in the valuation allowance related to the Insignia unrealized impairment loss, and state income tax expense. During the
six
-month period ended
September 30, 2016,
the Company recorded
$3,000
in income tax expense which resulted in an effective tax rate of -
0.1%.
The individually largest factor contributing to the difference between the federal statutory rate and the Company’s effective tax rate for the period ending
September 2016
was the recognition of a valuation allowance against Delphax’s pretax loss in the period. The income tax provision for the
six
-month period ended
September 30, 2016
differs from the federal statutory rate due also in part to the effect of state income taxes and the federal domestic production activities deduction. Additionally, the rate for the period ended
September 30, 2016
includes the estimated benefit for the exclusion of income for the Company’s captive insurance company subsidiary afforded under Section
831
(b).
 
As described in Note
9,
effective on
November 24, 2015,
Air T, Inc. purchased equity and debt interests in Delphax Technologies, Inc. (“Delphax”) and its subsidiary Delphax Technologies Canada Limited (“Delphax Canada”). With an equity investment level by the Company of approximately
38%,
Delphax is required to continue filing a separate United States corporate tax return. Furthermore, Delphax has
three
foreign subsidiaries located in Canada, France, and the United Kingdom which file tax returns in those jurisdictions. With few exceptions, Delphax is
no
longer subject to examinations by income tax authorities for tax years before
2012.
 
 
Delphax maintains a
September 30
fiscal year. As of
September 30, 2016,
Delphax and its subsidiaries had estimated foreign and domestic tax loss carryforwards of
$6.3
million and
$13.2
million, respectively. As of that date, they had estimated foreign research and development credit carryforwards of
$4.3
million, which are available to offset future income tax. The credits and net operating losses expire in varying amounts beginning in the year
2023.
Domestic alternative minimum tax credits of approximately
$311,000
are available to offset future income tax with
no
expiration date. Should there be an ownership change for purposes of Section
382
or any equivalent foreign tax rules, the utilization of the previously mentioned carryforwards
may
be significantly limited. As a result of the bankruptcy proceedings involving Delphax Canada
(see Note
9
), any remaining tax attributes
not
utilized during the fiscal year ended
September 30, 2017,
including net operating losses and credit carryforwards in Canada will be lost. The tax attributes in Canada that will be lost to the extent
not
utilized include, but are
not
limited to,
$4.0M
of net operating losses and
$4.3
million of foreign credits.  The Company has recorded an outside basis difference in stock of these entities of
$2.9
million which is the estimated loss that will be recognized in the United States upon their liquidation. See additional information regarding Delphax Canada in Note
9.
 
The provisions of ASC
740
require an assessment of both positive and negative evidence when determining whether it is more-likely-than-
not
that deferred tax assets will be recovered. In accounting for the Delphax acquisition on
November 24, 2015,
the Company established a full valuation allowance against Delphax
’s net deferred tax assets of approximately
$11,661,000.
The corresponding valuation allowance at
September 30, 2017
and
September 30, 2016
was approximately
$13,791,000
and
$12,770,000
respectively. The cumulative losses incurred by Delphax in recent years was the primary basis for the Company’s determination that a full valuation allowance should be established.
 
As described in Note
2,
effective on
July 18, 2016,
Air T, Inc. through its subsidiary, Contrail Aviation, acquired substantially all of the assets of the Seller for payment to the Seller of cash and equity membership units representing
21%
of the total equity of Contrail Aviation. The acquisition was treated as an asset acquisition for tax purposes, with Air T, Inc. receiving a step up on the
79%
interest deemed to be acquired. Contrail Aviation, a limited liability company, is taxed as a partnership with Air T, Inc. and the Seller recognizing on a pass-through basis the taxable income or loss of Contrail Aviation in proportion to their relative equity interests. Air T, Inc. will recognize deferred taxes as applicable on the outside basis difference of the investment.
 
As described in Note
2,
on
May 2, 2017
and
May 31, 2017,
AirCo acquired the inventory and principal business assets, and assumed specified liabilities, of the AirCo Sellers.
  The acquired business, which is based in Wichita, Kansas, distributes and sells airplane and aviation parts and maintains a license under Part
145
of the regulations of the Federal Aviation Administration. The consideration paid for the acquired business was
$2,400,000.
  A bargain purchase gain was recognized on the acquisition of approximately
$780,000.
The tax impact related to the bargain purchase gain was to record a deferred tax liability of approximately
$278,000
and record tax expense against the bargain purchase gain line of approximately
$278,000.
  The resulting net bargain purchase gain after taxes was approximately
$502,000.