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INCOME TAXES | 12 Months Ended
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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.

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- Definition The entire disclosure for income taxes. Disclosures may include net deferred tax liability or asset recognized in an enterprise's statement of financial position, net change during the year in the total valuation allowance, approximate tax effect of each type of temporary difference and carryforward that gives rise to a significant portion of deferred tax liabilities and deferred tax assets, utilization of a tax carryback, and tax uncertainties information. + References Reference 1: http://www.xbrl.org/2003/role/disclosureRef -Topic 946 -SubTopic 20 -Name Accounting Standards Codification -Section 50 -Paragraph 13 -Publisher FASB -URI https://asc.fasb.org//1943274/2147480990/946-20-50-13 Reference 2: http://www.xbrl.org/2003/role/disclosureRef -Topic 235 -SubTopic 10 -Name Accounting Standards Codification -Section S99 -Paragraph 1 -Subparagraph (SX 210.4-08(h)(2)) -Publisher FASB -URI https://asc.fasb.org//1943274/2147480678/235-10-S99-1 Reference 3: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -Name Accounting Standards Codification -Publisher FASB -URI https://asc.fasb.org//740/tableOfContent Reference 4: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -SubTopic 10 -Name Accounting Standards Codification -Section 50 -Paragraph 14 -Publisher FASB -URI https://asc.fasb.org//1943274/2147482685/740-10-50-14 Reference 5: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -SubTopic 10 -Name Accounting Standards Codification -Section 50 -Paragraph 21 -Publisher FASB -URI https://asc.fasb.org//1943274/2147482685/740-10-50-21 Reference 6: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -SubTopic 270 -Name Accounting Standards Codification -Section 50 -Paragraph 1 -Publisher FASB -URI https://asc.fasb.org//1943274/2147482526/740-270-50-1 Reference 7: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -SubTopic 10 -Name Accounting Standards Codification -Section 50 -Paragraph 17 -Subparagraph (b) -Publisher FASB -URI https://asc.fasb.org//1943274/2147482685/740-10-50-17 Reference 8: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -SubTopic 10 -Name Accounting Standards Codification -Section S99 -Paragraph 1 -Subparagraph (SAB TOPIC 6.I.5.Q1) -Publisher FASB -URI https://asc.fasb.org//1943274/2147479360/740-10-S99-1 Reference 9: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -SubTopic 10 -Name Accounting Standards Codification -Section S99 -Paragraph 2 -Subparagraph (SAB Topic 11.C) -Publisher FASB -URI https://asc.fasb.org//1943274/2147479360/740-10-S99-2 Reference 10: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -SubTopic 30 -Name Accounting Standards Codification -Section 50 -Paragraph 2 -Subparagraph (a) -Publisher FASB -URI https://asc.fasb.org//1943274/2147482603/740-30-50-2 + Details
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