INCOME TAXES

12 Months Ended

Dec. 31, 2023

INCOME TAXES

INCOME TAXES

10. INCOME TAXES

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

	Years Ended				Six Months Ended		Fiscal Year Ended
	December 31,		December 31,		December 31,		June 30,
	2023		2022		2021		2021
United States	$	64,105	$	86,321	$	68,239	$	130,175
Foreign		218,035		186,547		100,597		209,468
	$	282,140	$	272,868	$	168,836	$	339,643

Our Income tax expense consisted of (amounts in thousands):

	Years Ended				Six Months Ended		Fiscal Year Ended
	December 31,		December 31,		December 31,		June 30,
	2023		2022		2021		2021
Current:
Federal	$	24,046	$	29,228	$	19,285	$	38,146
State		(68)		467		(503)		867
Foreign		24,499		23,067		8,716		(2,602)
	$	48,477	$	52,762	$	27,498	$	36,411
Deferred and others:
Federal	$	(763)	$	(957)	$	104	$	376
State		(14)		(18)		2		(2)
Foreign		(5,692)		(18,861)		2,404		82
	$	(6,469)	$	(19,836)	$	2,510	$	456
Total income tax expense	$	42,008	$	32,926	$	30,008	$	36,867

The provision for income taxes for the years ended December 31, 2023 and 2022, six months ended December 31, 2021, and fiscal year ended June 30, 2021 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 (amounts in thousands):

	Years Ended				Six Months Ended		Fiscal Year Ended
	December 31,		December 31,		December 31,		June 30,
	2023		2022		2021		2021
Total expense computed by applying federal rates	$	59,249	$	57,303	$	35,456	$	71,325
State and provincial income taxes, net of federal benefit		625		545		518		874
Excess depletion		(2,259)		(1,907)		(1,363)		(1,812)
Estimates for uncertain tax positions		—		—		(910)		(26,179)
Statutory tax attributable to non-controlling interest		(224)		(363)		(219)		(72)
Effect of foreign earnings		(10,116)		(8,846)		(3,896)		(7,659)
Unrealized foreign exchange gains		(988)		853		54		(616)
Rate adjustment		(6)		—		1,694		—
Changes in estimates		11		119		(2,614)		(858)
Valuation allowance		(6,030)		(15,877)		833		1,284
Other		1,746		1,099		455		580
Total income tax expense	$	42,008	$	32,926	$	30,008	$	36,867

The effective tax rate for the year ended December 31, 2023, was 14.9% which included the release of a valuation allowance on certain foreign deferred tax assets. The effective tax rate for the year ended December 31, 2022, was 12.1%, which included the release of a valuation allowance on certain foreign deferred tax assets. The effective tax rate for six months ended December 31, 2021, was 17.8% which included the release of an uncertain tax position resulting from settlement agreements with foreign tax authorities and a change in estimates, partially offset by a foreign tax rate adjustment resulting in the revaluation of certain deferred tax assets. The effective tax rate for the fiscal year ended June 30, 2021, was 10.9%, primarily impacted by the release of uncertain tax positions resulting from settlement agreements with foreign tax authorities.

The tax effects of temporary differences and carryforwards, which give rise to our deferred tax assets and liabilities on December 31, 2023 and 2022 are as follows (amounts in thousands):

	December 31,		December 31,
	2023		2022
Deferred tax assets:
Stock-based compensation	$	1,952	$	1,846
Net operating losses		4,683		3,184
Foreign tax credits		35,751		33,301
Amortizable tax goodwill		46,821		52,783
Other		5,044		4,575
Total deferred tax assets		94,251		95,689
Valuation allowance		(40,814)		(46,844)
Net deferred tax assets	$	53,437	$	48,845
Deferred tax liabilities:
Mineral property basis	$	(122,543)	$	(124,373)
Unrealized foreign exchange gains		(582)		(582)
Other		(97)		(143)
Total deferred tax liabilities		(123,222)		(125,098)
Total net deferred taxes	$	(69,785)	$	(76,253)

We review the measurement of our deferred tax assets at each balance sheet date. Considering all available positive and negative evidence, including but not limited to recent earnings history and forecasted future results, the Company believes it is more likely-than-not that all net deferred tax assets not currently burdened with a valuation allowance will be fully realized. As of December 31, 2023 and 2022, we recorded a valuation allowance of $40.8 million and $46.8 million, respectively. The valuation allowance remaining at December 31, 2023 is attributable to US foreign tax credits of $35.8 million and capital losses of $1.9 million and other tax attribute carryforwards of $3.2 million in non-US subsidiaries.

As of December 31, 2023 and 2022, we had $4.7 million and $3.2 million of net operating loss carryforwards. The majority of the tax loss carryforwards are in jurisdictions that allow a twenty-year carry-forward period. As a result, these losses do not begin to expire until the 2038 tax year, and the Company anticipates the losses will be fully utilized.

As of December 31, 2023 and 2022, we had zero unrecognized tax benefits. A reconciliation of the beginning and ending amount of gross unrecognized tax benefits for the years ended December 31, 2023 and 2022, six months ended December 31, 2021, and fiscal year ended June 30, 2021 is as follows (amounts in thousands):

	Years Ended				Six Months Ended		Fiscal Year Ended
	December 31,		December 31,		December 31,		June 30,
	2023		2022		2021		2021
Total gross unrecognized tax benefits at beginning of year	$	—	$	—	$	652	$	25,389
Additions / Reductions for tax positions of current year		—		—		—		—
Additions / Reductions for tax positions of prior years		—		—		(60)		(812)
Reductions due to settlements with taxing authorities		—		—		(592)		(23,925)
Total amount of gross unrecognized tax benefits at end of year	$	—	$	—	$	—	$	652

We file 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 2020.

Our continuing practice is to recognize interest and/or penalties related to unrecognized tax benefits as part of our income tax expense. For the years ended December 31, 2023 and 2022, and the six months ended December 31, 2021, the amount of accrued income-tax-related interest and penalties was zero. For the fiscal year ended June 30, 2021, the accrued income-tax-related interest and penalties was $0.3 million. The gross unrecognized tax benefits reflected in the tabular reconciliation do not include interest and penalties.