Income Taxes

The components of the provision for income taxes are as follows:



	Years Ended December 31,
	2016		2015		2014
($ in thousands)
Current
Federal	$	12,790	$	28,077	$	31,787
State	1,855		2,539		3,168
Total current tax expense	14,645		30,616		34,955
Deferred
Federal	5,489		4,339		3,200
State	910		2,017		1,194
Total deferred tax expense	6,399		6,356		4,394
Total expense for income taxes	$	21,044	$	36,972	$	39,349

The following presents a reconciliation of the provision (benefit) for income taxes computed at the federal statutory rate to the provision (benefit) for income taxes recognized in the Consolidated Statements of Operations for the years indicated:



	Years Ended December 31,
	2016					2015				2014
($ in thousands)
Tax at statutory rate	$	24,432		35	%	$	23,675	35	%	$	47,922		35	%
State taxes, net of federal benefit	2,010			3		2,717		4		4,357			3
Uncertain tax positions	—			—		—		—		(30,961		)	(22	)
IRS audit resolution	—			—		—		—		15,505			11
Effect of net income attributable to noncontrolling interests	(91		)	—		1,492		2		—			—
Change in valuation allowance	(5,125		)	(7	)	7,812		12		2,165			2
Other, net	(182		)	(1	)	1,276		2		361			—
Income tax expense	$	21,044		30	%	$	36,972	55	%	$	39,349		29	%

The provision for income taxes reflects U.S. federal, state and local taxes at an estimated effective tax rate of 30%, 55% and 29% for the years ended December 31, 2016, 2015 and 2014, respectively. The Company's tax position for the years ended December 31, 2016 and 2015 was impacted by changes in the valuation allowance related to the unrealized and realized gain/loss position on the Company’s marketable securities. Additionally, the Company’s effective tax rate for the year ended December 31, 2014 was impacted by a net tax benefit of approximately $15.5 million due to the resolution of an Internal Revenue Service (“IRS”) examination of the Company's 2011 federal consolidated corporate income tax return. The net benefit is comprised of the recognition of tax benefits from previously uncertain tax positions of approximately $31.0 million and a reduction in the available loss deduction of approximately $15.5 million, of which both related to the past dissolution of a subsidiary.

Deferred taxes resulted from temporary differences between the amounts reported in the consolidated financial statements and the tax basis of assets and liabilities. The tax effects of temporary differences are as follows:



	December 31,
	2016			2015
($ in thousands)
Deferred tax assets:
Intangible assets	$	19,348		$	27,728
Net operating losses	20,272			20,591
Compensation accruals	8,854			7,804
Capitalized transaction costs	10,022			8,704
Unrealized loss	5,291			12,157
Other	1,394			118
Gross deferred tax assets	65,181			77,102
Valuation allowance	(5,731		)	(10,855		)
Gross deferred tax assets after valuation allowance	59,450			66,247
Deferred tax liabilities:
Intangible assets	(11,915		)	(12,104		)
Gross deferred tax liabilities	(11,915		)	(12,104		)
Deferred tax assets, net	$	47,535		$	54,143

At each reporting date, the Company evaluates the positive and negative evidence used to determine the likelihood of realization of its deferred tax assets. The Company maintained a valuation allowance in the amount of $5.7 million and $10.9 million at December 31, 2016 and 2015, respectively, relating to deferred tax assets on items of a capital nature as well as certain state deferred tax assets.

As of December 31, 2016, the Company had net operating loss carry-forwards for federal income tax purposes represented by a $14.1 million deferred tax asset. The related federal net operating loss carry-forwards are scheduled to begin to expire in the year 2031. As of December 31, 2016, the Company had state net operating loss carry-forwards, varying by subsidiary and jurisdiction, represented by a $6.2 million deferred tax asset. The state net operating loss carry-forwards are scheduled to begin to expire in 2017.

Internal Revenue Code Section 382 limits tax deductions for net operating losses, capital losses and net unrealized built-in losses after there is a substantial change in ownership in a corporation’s stock involving a 50 percentage point increase in ownership by 5% or larger stockholders. During the year ended December 31, 2009, the Company incurred an ownership change as defined in Section 382. At December 31, 2016, the Company has pre-change losses, represented by deferred tax assets totaling $21.4 million. The utilization of these assets in subject to an annual limitation of $1.6 million.

Activity in unrecognized tax benefits is as follows:



	Years Ended December 31,
	2016		2015		2014
($ in thousands)
Balance, beginning of year	$	—	$	—	$	32,602
Decrease related to tax positions taken in prior years	—		—		(32,602		)
Increase related to positions taken in the current year	—		—		—
Balance, end of year	$	—	$	—	$	—

The Company’s practice is to classify interest and penalties related to income tax matters in income tax expense. The Company recorded no interest or penalties related to unrecognized tax benefits at December 31, 2016, 2015 and 2014.

During the year ended December 31, 2016, the Company experienced a tax shortfall of $1.3 million related to certain stock-based incentive plans. Under ASC 718, these tax shortfalls are able to be offset to the extent of the accumulated windfall deductions recorded in stockholders equity in the Company's Consolidated Balance Sheet.

The earliest federal tax year that remains open for examination is 2008 since net operating loss carry-forwards from 2008 could be denied when claimed in future years. The earliest open years in the Company’s major state tax jurisdictions are 2008 for Connecticut and 2012 for all of the Company's remaining state tax jurisdictions.