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INCOME TAXES
12 Months Ended
Jun. 30, 2017
INCOME TAXES  
INCOME TAXES

10. INCOME TAXES

For financial reporting purposes, Income (loss) before income taxes includes the following components:

 

 

 

 

 

 

 

 

 

 

 

 

Fiscal Year Ended June 30, 

 

 

2017

 

2016

 

2015

 

 

(Amounts in thousands)

United States

    

$

15,253

    

$

(230)

    

$

17,569

Foreign

 

 

103,613

 

 

(21,528)

 

 

44,675

 

 

$

118,866

 

$

(21,758)

 

$

62,244

 

The Company’s Income tax expense consisted of:

 

 

 

 

 

 

 

 

 

 

 

 

Fiscal Year Ended June 30, 

 

 

2017

 

2016

 

2015

 

 

(Amounts in thousands)

Current:

    

 

  

    

 

  

    

 

  

Federal

 

$

13,975

 

$

45,878

 

$

22,418

State

 

 

308

 

 

135

 

 

(36)

Foreign

 

 

10,602

 

 

19,650

 

 

14,835

 

 

$

24,885

 

$

65,663

 

$

37,217

Deferred and others:

 

 

  

 

 

  

 

 

  

Federal

 

$

(1,443)

 

$

(6,986)

 

$

(5,506)

State

 

 

(18)

 

 

(78)

 

 

(49)

Foreign

 

 

3,017

 

 

2,081

 

 

(22,096)

 

 

$

1,556

 

$

(4,983)

 

$

(27,651)

Total income tax expense

 

$

26,441

 

$

60,680

 

$

9,566

 

The provision for income taxes for the fiscal years ended June 30, 2017, 2016 and 2015, differs from the amount of income tax determined by applying the applicable United States statutory federal income tax rate to pre‑tax income (net of non‑controlling interest in income of consolidated subsidiary and loss from equity investment) from operations as a result of the following differences:

 

 

 

 

 

 

 

 

 

 

 

 

Fiscal Year Ended June 30, 

 

 

2017

 

2016

 

2015

 

 

(Amounts in thousands)

Total expense computed by applying federal rates

    

$

41,603

    

$

(7,615)

    

$

21,786

State and provincial income taxes, net of federal benefit

 

 

78

 

 

(1)

 

 

25

Excess depletion

 

 

(1,517)

 

 

(882)

 

 

(1,429)

Estimates for uncertain tax positions

 

 

2,870

 

 

1,866

 

 

1,404

Statutory tax attributable to non-controlling interest

 

 

3,162

 

 

1,838

 

 

(211)

Effect of foreign earnings

 

 

3,046

 

 

61,576

 

 

6,536

Effect of foreign earnings indefinitely reinvested

 

 

(22,922)

 

 

3,406

 

 

(7,601)

Canadian rate adjustment

 

 

 —

 

 

 —

 

 

4,070

Chilean tax reform

 

 

 —

 

 

 —

 

 

(2,481)

Unrealized foreign exchange gains

 

 

(746)

 

 

(2,439)

 

 

(10,949)

Changes in estimates

 

 

(3,676)

 

 

1,641

 

 

(359)

Valuation allowance

 

 

4,374

 

 

849

 

 

 —

Other

 

 

169

 

 

441

 

 

(1,225)

 

 

$

26,441

 

$

60,680

 

$

9,566

 

The effective tax rate includes the impact of certain undistributed foreign subsidiary earnings for which we have not provided U.S. taxes because we plan to reinvest such earnings indefinitely outside the United States. The Company has the ability and intent to indefinitely reinvest these foreign earnings based on revenue and cash projections of our other investments, current cash on hand, and availability under our revolving credit facility. No deferred tax has been provided on the difference between the tax basis in the stock of the consolidated subsidiary and the amount of the subsidiary’s net equity determined for financial reporting purposes.

The tax effects of temporary differences and carryforwards, which give rise to our deferred tax assets and liabilities at June 30, 2017 and 2016, are as follows:

 

 

 

 

 

 

 

 

 

2017

 

2016

 

 

(Amounts in thousands)

Deferred tax assets:

    

 

  

    

 

  

Stock-based compensation

 

$

5,979

 

$

5,691

Net operating losses

 

 

5,341

 

 

12,385

Foreign tax credits

 

 

19,869

 

 

 —

Other

 

 

7,382

 

 

4,610

Total deferred tax assets

 

 

38,571

 

 

22,686

Valuation allowance

 

 

(6,474)

 

 

(2,100)

Net deferred tax assets

 

$

32,097

 

$

20,586

Deferred tax liabilities:

 

 

  

 

 

  

Mineral property basis

 

$

(122,870)

 

$

(127,337)

Unrealized foreign exchange gains

 

 

(1,097)

 

 

(1,273)

2019 Notes

 

 

(8,634)

 

 

(12,639)

Investment in the Peak Gold JV

 

 

(5,475)

 

 

 —

Other

 

 

(595)

 

 

(124)

Total deferred tax liabilities

 

 

(138,671)

 

 

(141,373)

Total net deferred taxes

 

$

(106,574)

 

$

(120,787)

 

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 assets will not be realized.  As of June 30, 2017 and 2016, the Company had $6.5 million and $2.1 million of valuation allowances recorded, respectively.  The valuation allowance remaining at June 30, 2017 is attributable to US foreign tax credits and capital loss carryforwards in non‑US subsidiaries.

At June 30, 2017 and 2016, the Company had $32.1 million and $59.5 million of net operating loss carry forwards, respectively. The decrease in the net operating loss carry forwards is primarily attributable to the utilization of net operating losses by non‑U.S. subsidiaries.  The majority of the tax loss carry forwards are in jurisdictions that allow a twenty year carry forward period.  As a result, these losses do not begin to expire until the 2028 tax year, and the Company anticipates the losses will be fully utilized.

As of June 30, 2017 and 2016, the Company had $28.5 million and $26.9 million of unrecognized tax benefits, respectively.  If recognized, these unrecognized tax benefits would positively impact the Company’s effective income tax rate. A reconciliation of the beginning and ending amount of gross unrecognized tax benefits is as follows:

 

 

 

 

 

 

 

 

 

 

 

 

2017

 

2016

 

2015

 

 

(Amounts in thousands)

Total gross unrecognized tax benefits at beginning of year

    

$

26,960

    

$

26,120

    

$

23,956

Additions / Reductions for tax positions of current year

 

 

1,394

 

 

840

 

 

2,421

Additions / Reductions for tax positions of prior years

 

 

188

 

 

 —

 

 

 —

Reductions due to settlements with taxing authorities

 

 

 —

 

 

 —

 

 

(257)

Reductions due to lapse of statute of limitations

 

 

 —

 

 

 —

 

 

 —

Total amount of gross unrecognized tax benefits at end of year

 

$

28,542

 

$

26,960

 

$

26,120

 

The Company or one of its subsidiaries files income tax returns in the U.S. federal jurisdiction, and various state and foreign jurisdictions.  With few exceptions, the Company is no longer subject to U.S. Federal, state and local, and non‑U.S. income tax examinations by tax authorities for fiscal years before 2013. As a result of (i) statutes of limitation that will begin to expire within the next 12 months in various jurisdictions, (ii) possible settlements of audit‑related issues with taxing authorities in various jurisdictions with respect to which none of the issues are individually significant, and (iii) additional accrual of exposure and interest on existing items, the Company believes that it is reasonably possible that the total amount of its net unrecognized income tax benefits will not decrease in the next 12 months.

The Company’s continuing practice is to recognize interest and/or penalties related to unrecognized tax benefits as part of its income tax expense.  At June 30, 2017 and 2016, the amount of accrued income‑tax‑related interest and penalties was $6.8 million and $5.7 million, respectively.  The gross unrecognized tax benefits reflected in the tabular reconciliation do not include interest and penalties and are not reduced by advanced deposits of $9.7 million made to taxing authorities.