XML 39 R31.htm IDEA: XBRL DOCUMENT v3.26.1
INCOME TAXES
6 Months Ended
Jun. 30, 2026
Income Tax Disclosure [Abstract]  
INCOME TAXES:

20. INCOME TAXES:

The Company is subject to income taxes in both the United States and foreign jurisdictions. The effective income tax rate was 19.0% and 19.8% for the three months ended June 30, 2026 and 2025, respectively, and 19.7% for both six months ended June 30, 2026 and 2025. The Company recorded income tax expense of $11.6 million and $16.6 million for the three months ended June 30, 2026 and 2025, respectively, and $21.0 million and $32.3 million for the six months ended June 30, 2026 and 2025, respectively. The discrepancy between the statutory tax rate and the effective tax rate was primarily due to the benefit of income taxed in foreign jurisdictions and the use of research and development credits. As of June 30, 2026 and December 31, 2025 the Company had $25.1 million and $57.0 million, respectively, of taxes receivable included in other current assets on the Consolidated Balance Sheets. In January 2026, the Company received $39.0 million of the taxes receivable as of December 31, 2025 from the United States Treasury.

In assessing the realizability of deferred tax assets, management considers whether it is more likely than not that some portion or all of the deferred tax assets will not be realized. The ultimate realization of deferred tax assets is dependent on the Company's ability to generate future taxable income to obtain benefit from the reversal of temporary differences, net operating loss carryforwards and tax credits. As part of its assessment, management considers the scheduled reversal of deferred tax liabilities, projected future taxable income, and tax planning strategies. As of June 30, 2026, there was not sufficient evidence to release the valuation allowance that has been recorded for the New Jersey research and development credits and unrealized loss on investments. There are no indicators against the realizability of the remaining net deferred tax asset.

On December 27, 2018, the Korean Supreme Court, citing prior cases, held that only royalties paid with respect to Korean registered patents are considered Korean source income and subject to Korean withholding tax under the applicable law and interpretation of the Korea-U.S. Tax Treaty. The Company has incurred Korean withholding tax of $14.9 million for each of the years ended December 31, 2018, through December 31, 2022. Based on the Korean Supreme Court decision, a tax refund request on behalf of the Company was filed with the Korean National Tax Service (KNTS) for the period from January 1, 2018, to December 31, 2022. The Company received a formal rejection from the KNTS, and in May 2022 filed an appeal with the Korean Tax Tribunal. On December 18, 2023, the Company received a formal rejection from the Tax Tribunal. Anticipating the rejection of the appeal, in September 2023 the Company filed a petition to the District Court.

On September 18, 2025, the Korean Supreme Court issued a decision, changing its long-standing position on the taxation of royalties for patents not registered in Korea. The court held that royalties paid for licensing of a patent constitute Korean source income if the patented technology is actually used in the territory of the Republic of Korea. Based on discussions with a prominent Korean law firm, the Company has been advised that there is still a more likely-than-not chance of success, as the manufacturing and sales process occurs within and without the Republic of Korea. During a court appearance in March 2026, the judge requested additional information from the Korean Tax Authority, regarding what amount of royalties would be considered to be related to use in Korea. The Korean Tax Authority has not produced the requested information and, therefore, the scheduled July 2026 hearing was postponed without a specific future date.

The Company has recorded a long-term receivable of $50.3 million and $53.8 million as of June 30, 2026, and December 31, 2025, respectively, for the receipt of the Korean withholding tax. The Company also recorded a foreign exchange loss of $476,000 and a foreign exchange gain of $4.5 million for the three months ended June 30, 2026 and 2025, respectively, and a foreign exchange loss of $3.5 million and a foreign exchange gain of $4.5 million for the six months ended June 30, 2026 and 2025, respectively, due to the fluctuation of the Korean Won to the U.S. Dollar and resulting remeasurement of this Won-denominated receivable. The Company will amend U.S. federal tax returns for the 2018 to 2022 years when the anticipated refund from KNTS is received to offset the additional tax liability. The Company has recorded a long-term payable of $15.7 million as of June 30, 2026 and December 31, 2025, for the estimated amounts due to the U.S. federal government based on the amendment of the Company's U.S. tax returns, indicating that lower withholding amounts were required.

The Company is not subject to examinations by the federal tax authority for the years prior to 2022. The Company's state and foreign tax returns are open for a period of generally three to four years. The Company is currently under IRS tax audit for 2023, and under California tax audit for 2021 and 2022. As of June 30, 2026, no adjustments have been proposed for these ongoing audits.

The above estimates may change in the future and upon settlement.