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Income Taxes (Notes)
9 Months Ended
Sep. 30, 2012
Income Tax Disclosure [Abstract]  
Income Taxes [Text Block]
3.
INCOME TAXES
Rayonier is a real estate investment trust ("REIT"). In general, only the taxable REIT subsidiaries, whose businesses include the Company's non-REIT qualified activities, are subject to corporate income taxes. However, the Company is subject to U.S. federal corporate income tax on built-in gains (the excess of fair market value over tax basis for property held upon REIT election at January 1, 2004) on taxable sales of such property during calendar years 2004 through 2010 and 2012 through 2013. In 2011, the law provided a built-in-gains tax holiday. Accordingly, the provision for corporate income taxes relates principally to current and deferred taxes on taxable REIT subsidiaries' income and certain property sales.
Unrecognized Tax Benefits
During the third quarter of 2011, the Company received a final examination report from the U.S. Internal Revenue Service ("IRS") regarding Rayonier TRS Holdings Inc. ("TRS") 2009 tax return. As a result, the Company reversed the uncertain tax liability recorded in 2009 relating to the taxability of the alternative fuel mixture credit and recognized a $16 million tax benefit in the third quarter of 2011.
Alternative Fuel Mixture Credit ("AFMC") and Cellulosic Biofuel Producer Credit ("CBPC")
The U.S. Internal Revenue Code allowed two credits for taxpayers that produced and used an alternative fuel in the operation of their business through December 31, 2009. The AFMC is a $.50 per gallon refundable, non-taxable excise tax credit, while the CBPC is a $1.01 per gallon credit that is nonrefundable, taxable and has limitations based on an entity's tax liability. Rayonier produces and uses an alternative fuel ("black liquor") at its Jesup, Georgia and Fernandina Beach, Florida Performance Fibers mills, which qualified for both credits. The Company claimed the AFMC on its 2009 tax return.
In the third quarters of 2012 and 2011, management approved the exchange of approximately 22 million gallons and 11 million gallons, respectively, of black liquor previously claimed for the AFMC for the CBPC. The total number of exchange gallons approved year-to-date were 82 million and 41 million for 2012 and 2011, respectively. The third quarter impact of the exchange was $2.6 million and $2.0 million for 2012 and 2011, respectively. The year-to-date impact was $11.7 million and $6.1 million for 2012 and 2011, respectively. For additional information on the AFMC and CBPC, see Note 8 — Income Taxes in the Company's Annual Report on Form 10-K for the year ended December 31, 2011.
During the second quarter 2012, Rayonier recognized $3.4 million of interest expense related to the exchange; however, in August, the IRS released guidance stating interest payments are not required for AFMC funds exchanged for the CBPC, based upon the manner of the Company's original claim. As a result, in the third quarter Rayonier reversed the $3.4 million of interest expense previously recorded.
Effective Tax Rate
The Company's effective tax rate is below the 35 percent U.S. statutory tax rate primarily due to tax benefits associated with being a REIT. The Company's effective tax rates in 2012 were higher than 2011. The change was primarily due to tax benefits received in 2011, including the reversal of the reserve related to the taxability of the AFMC and a $9.3 million benefit associated with the structuring of a transfer of higher and better use properties to the taxable REIT subsidiary from the REIT.
The tables below reconcile the U.S. statutory rate to the Company's effective tax rate for each period presented (in millions of dollars).
 
Three Months Ended September 30,
 
2012
 
2011
Income tax expense at federal statutory rate
$
37

 
35.0
 %
 
$
34

 
35.0
 %
REIT income not subject to tax
(6
)
 
(5.7
)%
 
(11
)
 
(11.3
)%
Other
(3
)
 
(2.9
)%
 
(4
)
 
(3.7
)%
Income tax expense before non-routine items
28

 
26.4
 %
 
19

 
20.0
 %
AFMC for CBPC exchange
(3
)
 
(3.0
)%
 
(2
)
 
(2.1
)%
AFMC reserve reversal

 

 
(16
)
 
(16.6
)%
Installment note prepayment

 

 
(9
)
 
(9.3
)%
Built-in gains tax holiday

 

 
(1
)
 
(1.0
)%
Income tax expense (benefit) as reported
$
25

 
23.4
 %
 
$
(9
)
 
(9.0
)%
 
Nine Months Ended September 30,
 
2012
 
2011
Income tax expense at federal statutory rate
$
91

 
35.0
 %
 
$
83

 
35.0
 %
REIT income not subject to tax
(18
)
 
(7.0
)%
 
(25
)
 
(10.6
)%
Other
(4
)
 
(1.6
)%
 
(5
)
 
(1.9
)%
Income tax expense before non-routine items
69

 
26.4
 %
 
53

 
22.5
 %
AFMC for CBPC exchange
(12
)
 
(4.5
)%
 
(6
)
 
(2.6
)%
AFMC reserve reversal

 

 
(16
)
 
(6.7
)%
Installment note prepayment

 

 
(9
)
 
(3.9
)%
Built-in gains tax holiday

 

 
(4
)
 
(1.8
)%
Income tax expense as reported
$
57

 
21.9
 %
 
$
18

 
7.5
 %