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Income Taxes
12 Months Ended
Dec. 31, 2021
Income Tax Disclosure [Abstract]  
Income Taxes
14. Income Taxes
The Company’s loss before income taxes consisted of (in millions):
 
    
Year Ended December 31,
 
    
2021
    
2020
    
2019
 
United States
   $
 (496.5
)
 
   $ (272.4    $ (388.9
International
    
(0.1
)
 
     0.5        —    
    
 
 
    
 
 
    
 
 
 
Total
   $
(496.6
)
 
   $
 
(271.9    $
 
(388.9
    
 
 
    
 
 
    
 
 
 
For the year ended December 31
, 2021, the loss before
 income
taxes of $496.6 million includes $1.3 
million of losses from the Company’s equity investment in OriginPoint. The OriginPoint business operates in the United States.
The components of the Company’s income tax benefit (provision) consisted of (in millions):

 
  
Year Ended December 31,
 
 
  
2021
 
  
2020
 
  
2019
 
Current:
  
     
  
     
  
     
Federal
   $
 —  
     $ 0.8      $ —    
State
    
—  
       —          —    
Foreign
    
(1.2
)
 
     (0.2      —    
    
 
 
    
 
 
    
 
 
 
Total current
    
(1.2
)
 
     0.6        —    
Deferred:
                          
Federal
    
2.1
       0.3        1.0  
State
    
0.4
       0.6        (0.1
Foreign
    
1.2
       0.2        —    
Total deferred
    
3.7
       1.1        0.9  
    
 
 
    
 
 
    
 
 
 
Total benefit from income taxes
   $
2.5
     $ 1.7      $
 
0.9  
    
 
 
    
 
 
    
 
 
 
The Company had an income tax benefit for
the years ended December 31, 2021, 2020 and 2019,
resulting
from a partial reduction in the valuation allowance related to the carryover tax basis in deferred tax liabilities from acquisitions and current taxes in India
that is
fully offset with future AMT tax credits.
The effective income tax rate differed from the statutory federal income tax
rate as follows:
 
 
  
Year Ended December 31,
 
 
  
2021
 
 
2020
 
 
2019
 
Tax at federal statutory rate
     21.0     21.0     21.0
State taxes, net of federal effect
     8.8     4.0     7.7
Change in valuation allowance
     (34.2 )
%
    (23.4 )%      (28.6 )% 
Stock-based compensation
     7.9     0.0     0.8
Non-deductible executive compensation
     (2.8 )%      0.0     0.0
Non-deductible
expenses
     0.1     (2.1 )%      (0.6 )%
Other
     (0.3 )
%
    1.1     (0.1 )% 
    
 
 
   
 
 
   
 
 
 
Benefit from
income taxes
     0.5     0.6     0.2
    
 
 
   
 
 
   
 
 
 
The components of net deferred taxes arising from temporary differences were as follows (in millions):
 
    
December 31,
 
    
2021
    
2020
 
Deferred tax assets:
                 
Nondeductible accruals
   $
15.0
 
   $ 7.8  
Stock-based compensation
    
66.7
 
     20.0  
Lease liabilities
    
157.9
 
     144.6  
Net operating loss carryforward
    
331.1
 
     240.4  
Allowance for credit losses
    
7.2
 
     7.3  
Accrued compensation
    
32.5
 
     18.6  
Other
    
3.4
 
     1.4  
    
 
 
 
  
 
 
 
Total deferred tax assets
    
613.8
 
     440.1  
    
 
 
 
  
 
 
 
Deferred tax liabilities:
                 
Operating lease
right-of-use
assets
    
(132.8
     (119.9
Intangible assets
    
(1.7
     (6.1
Property and equipment
    
(29.5
     (26.4
    
 
 
 
  
 
 
 
Total deferred tax liabilities
    
(164.0
     (152.4
    
 
 
 
  
 
 
 
Less: valuation allowance
     (4
48
.4
)

     (287.5
    
 
 
 
  
 
 
 
Net deferred tax assets
   $ 1.4
 
   $ 0.2  
    
 
 
    
 
 
 
The Company is subject to income taxes in the United States and India. Deferred income taxes reflect the net tax effects of (a) temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for income tax purposes and (b) operating losses and tax credit carryforwards.
As of December 31, 2021 and 2020, the Company’s deferred tax assets were primarily the result of U.S. federal and state net operating losses, operating lease obligations, stock-based compensation and compensation and other expense related accruals. A full valuation allowance was maintained against its U.S. gross deferred tax asset balances as of December 31, 2021 and 2020. As of each reporting date, the Company considers new evidence, both positive and negative, that could impact the Company’s view with regard to future realization of deferred tax assets. As of December 31, 2021 and 2020, the Company continued to maintain that the realization of its deferred tax assets has not achieved
a more-likely-than-not threshold
primarily due to the evidence that the Company continued to maintain three-year
cumulative pre-tax book
losses. As of December 31, 2021, the valuation allowance was in the amount of approximately
$448.4 million, an increase of $160.9 million from December 31, 
2020, which includes the impact of acquisition activity. 
As of December 31, 2021 and 2020, the Company had approximately $1.2 
billion
and $882.5 million of gross federal net operating losses, respectively. Of those amounts, $151.7 million will begin to expire in 2032 and
$1 billion
have an unlimited carryforward with utilization limited at 80% of taxable income. Such amounts may be subject to an annual limitation under Section 382 of the Internal Revenue Code of 1986, as amended, as a result of various ownership change rules.
As of December 31, 2021 and 2020, the Company had approximately $1.2 
billion
and $870.7 million of state net operating losses, respectively, that will begin to expire in 2029.
The Company had
 no uncertain tax positions as of
 
December 31, 2021, 2020 and 2019
. The Company does not anticipate a significant increase or decrease in the uncertain tax positions in the next twelve months after the reporting period. It is the Company’s policy to record interest and penalties related to uncertain tax positions as a component of the provision for income taxes. No amounts of interest or penalties were recognized in the consolidated financial statements for the years ended December 31, 2021, 2020 and 2019.
The Company has obtained an income tax holiday in India
,
which expires in 2024. This incentive is conditional on meeting certain direct investment thresholds. If the Company fails to satisfy the conditions, the Company may be required to refund previously realized benefits. The Company does not expect these amounts to be material to the Company’s consolidated financial statements.
The number of years with open tax audits varies depending upon the tax jurisdiction. The Company is generally no longer subject to
U.S. federal
examination by the Internal Revenue Service (“IRS”) for years before 201
5
. The IRS and state taxing authorities can subject the Company to audit dating back to 2012 when the Company begins to utilize its net operating loss carryforwards.