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INCOME TAXES
 9 Months Ended
Sep. 30, 2023
Income Tax Disclosure [Abstract]  
INCOME TAXES INCOME TAXES
The Company calculates the tax provision for interim periods using an estimated annual effective tax rate applied to year-to-date ordinary income and adjusts for discrete items in the quarter. In each quarter, the estimate of the annual effective tax rate is updated and an adjustment is made in the year-to-date provision. The annual effective tax rate is subject to fluctuation due to factors including changing assumptions on forecasted annual pretax income, certain book and tax differences, valuation allowances against deferred tax assets, or changes in or interpretation of tax laws. The Company’s effective tax rate (“ETR”) can be volatile based on the amount of pretax income or loss in the period. For example, when pretax income is lower, the effect of non-deductible expenses or other discrete items will have a greater impact on the effective tax rate.
The Company’s ETR for the three months ended September 30, 2023 and 2022 was 106.5% and 15.4%, respectively. The ETR of 106.5% for the three months ended September 30, 2023 was higher than the U.S. statutory rate of 21.0% primarily due to a lower estimated annual effective tax rate applied to year-to-date losses and an increase in the Company’s valuation allowance associated with impairment charges, partially offset by an increase in the Company’s deductible stock-based compensation. The Company’s ETR for the nine months ended September 30, 2023 and 2022 was 14.9% and 17.1%, respectively. The ETR of 14.9% for the nine months ended September 30, 2023 was lower than the U.S. statutory rate of 21.0% primarily due to non-deductible stock compensation expense and tax on non-U.S. earnings, offset by a partial release of a valuation allowance on deferred tax assets associated with impairment charges.
As of December 31, 2022, the Company had a valuation allowance of $177.2 million recorded against its deferred capital loss tax asset balance of $225.2 million. The Company’s capital loss tax asset is comprised primarily of impairment charges related to crypto assets held and strategic investments made by Coinbase Ventures. As of each reporting date, management considers new evidence, both positive and negative, that could affect its view of the future realization of deferred tax assets. As of September 30, 2023, because crypto asset appreciation during the year provided more gains to offset losses, management determined that there is sufficient positive evidence to conclude that it is more likely than not that additional deferred taxes of $40.0 million are realizable, resulting in a net partial valuation allowance release of $40.0 million for the year.