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Income Taxes (Notes)
6 Months Ended
Jun. 30, 2013
Income Tax Disclosure [Abstract]  
Income Taxes [Text Block]
4.
INCOME TAXES
Rayonier is a real estate investment trust (“REIT”). In general, only its taxable REIT subsidiaries, whose businesses include the Company’s non-REIT qualified activities, and foreign operations are subject to corporate income taxes. However, the Company was 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. In 2011, the law provided a built-in-gains tax holiday. In 2013, the law provided a built-in gains tax holiday for 2012 (retroactive) and 2013. Accordingly, the provision for corporate income taxes relates principally to current and deferred taxes on taxable REIT subsidiaries’ income and foreign operations.
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 tax credit (which is not taxable), 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 first quarter of 2013 and the second quarter of 2012, management approved the exchange of approximately 120 million and 60 million gallons respectively, of black liquor previously claimed for the AFMC for the CBPC. As a result, the Company recorded a $19 million tax benefit in first quarter 2013. The second quarter 2012 impact of the exchange was a $9.1 million tax benefit partially offset by a $3.4 million interest expense accrual. The IRS later 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 such, Rayonier subsequently reversed the interest expense in third quarter 2012. 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, 2012.
Provision for Income Taxes from Continuing Operations
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 rate in 2013 was lower than 2012 primarily due to recording the additional AFMC exchange, the federal research and experimentation tax credit and a $4.9 million benefit associated with the completion of an internal transfer of properties.
The table below reconciles the U.S. statutory rate to the Company’s effective tax rate for each period presented (in millions of dollars):
 
Three Months Ended June 30,
 
2013
 
2012
Income tax expense at federal statutory rate
$
36

 
35.0
 %
 
$
27

 
35.0
 %
REIT income not subject to tax
(15
)
 
(14.3
)
 
(6
)
 
(8.7
)
Income tax expense before discrete items
21

 
20.7
 %
 
21

 
26.3
 %
Exchange of AFMC for CBPC

 

 
(9
)
 
(10.9
)
Other
(6
)
 
(5.9
)
 

 

Income tax expense as reported
$
15

 
14.8
 %
 
$
12

 
15.4
 %

 
Six Months Ended June 30,
 
2013
 
2012
Income tax expense at federal statutory rate
$
74

 
35.0
 %
 
$
52

 
35.0
 %
REIT income not subject to tax
(26
)
 
(12.4
)
 
(12
)
 
(8.1
)
Other
(2
)
 
(0.7
)
 
(1
)
 
(0.5
)
Income tax expense before discrete items
46

 
21.9
 %
 
39

 
26.4
 %
Exchange of AFMC for CBPC
(19
)
 
(8.9
)
 
(9
)
 
(6.0
)
Gain related to consolidation of New Zealand joint venture
(5
)
 
(2.7
)
 

 

Other
(2
)
 
(1.0
)
 

 

Income tax expense as reported
$
20

 
9.3
 %
 
$
30

 
20.4
 %

Provision for Income Taxes from Discontinued Operations
In the first quarter, Rayonier completed the sale of its Wood Products business for $80 million plus a working capital adjustment. For the six months ended June 30, 2013 and 2012, income tax expense related to discontinued operations was $22.3 million ($21.4 million from the gain on sale) and $1.9 million, respectively. For the three months ended June 30, 2012, income tax related to discontinued operations was $1.5 million. See Note 2Sale of Wood Products Business for additional information.