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INCOME TAXES | 12 Months Ended
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Dec. 31, 2021
Income Tax Disclosure [Abstract] |
INCOME TAXES | INCOME TAXES Rayonier is a REIT under the Internal Revenue Code and therefore generally does not pay U.S. federal or state income tax. As of December 31, 2021, Rayonier owns a 97.8% interest in the Operating Partnership and conducts substantially all of its timberland operations through the Operating Partnership. The taxable income or loss generated by the Operating Partnership is passed through and reported to its unitholders (including the Company) on a Schedule K-1 for inclusion in each unitholder’s income tax return. Certain operations, including log trading and certain real estate activities, such as the entitlement, development and sale of HBU properties, are conducted through our TRS. The TRS subsidiaries are subject to U.S. federal and state corporate income tax. The New Zealand timber operations are conducted by the New Zealand subsidiary, which is subject to corporate-level tax at 28% in New Zealand and is treated as a partnership for U.S. income tax purposes. PROVISION FOR INCOME TAXES FROM CONTINUING OPERATIONS The provision for income taxes for each of the three years ended December 31 follows:
| 2021 |  | 2020 |  | 2019 |
Current |  |  |  |  |  |
U.S. federal | ($1,893) |  |  | ($237) |  |  | $2 |  |
State | (536) |  |  | (339) |  |  | (122) |  |
Foreign | (11,425) |  |  | (5,391) |  |  | (1,542) |  |
| (13,854) |  |  | (5,967) |  |  | (1,662) |  |
Deferred |  |  |  |  |  |
U.S. federal | (6,288) |  |  | 8,355 |  |  | 465 |  |
State | (1,623) |  |  | 325 |  |  | 17 |  |
Foreign | (2,007) |  |  | (3,027) |  |  | (11,278) |  |
| (9,918) |  |  | 5,653 |  |  | (10,796) |  |
Changes in valuation allowance | 9,111 |  |  | (6,695) |  |  | (482) |  |
Total | ($14,661) |  |  | ($7,009) |  |  | ($12,940) |  |
A reconciliation of the U.S. federal statutory income tax rate to the actual income tax rate for each of the three years ended December 31 follows:
|  | 2021 |  | 2020 |  | 2019
U.S. federal statutory income tax rate |  | ($47,280) |  |  | (21.0) | % |  | ($7,726) |  |  | (21.0) | % |  | ($16,930) |  |  | (21.0) | %
U.S. and foreign REIT income |  | 44,316 |  |  | 19.7 |  |  | 16,569 |  |  | 45.0 |  |  | 19,902 |  |  | 24.7 |
Matariki Group and Rayonier New Zealand Ltd |  | (12,927) |  |  | (5.7) |  |  | (7,698) |  |  | (20.8) |  |  | (11,181) |  |  | (13.9) |
Change in valuation allowance |  | 9,111 |  |  | 4.0 |  |  | (6,695) |  |  | (18.2) |  |  | (482) |  |  | (0.6) |
REIT Built-in Gain |  | (2,215) |  |  | (1.0) |  |  | — |  |  | — |  |  | — |  |  | — |
State Net Operating Loss |  | — |  |  | — |  |  | 1,118 |  |  | 3.0 |  |  | — |  |  | — |
Prepaid land sales |  | — |  |  | — |  |  | (1,084) |  |  | (2.9) |  |  | — |  |  | — |
Internal transfer of assets deferred |  | — |  |  | — |  |  | — |  |  | — |  |  | (1,815) |  |  | (2.3) |
Foreign income tax withholding |  | (505) |  |  | (0.2) |  |  | (721) |  |  | (2.0) |  |  | (1,535) |  |  | (1.9) |
Sale of Timber Funds |  | (2,399) |  |  | (1.1) |  |  | — |  |  | — |  |  | — |  |  | — |
Other |  | (2,762) |  |  | (1.2) |  |  | (772) |  |  | (2.1) |  |  | (899) |  |  | (1.1) |
Income tax expense as reported for net income |  | ($14,661) |  |  | (6.5) | % |  | ($7,009) |  |  | (19.0) | % |  | ($12,940) |  |  | (16.1) | %
The Company’s effective tax rate is below the 21 percent U.S. statutory rate primarily due to tax benefits associated with being a REIT. DEFERRED TAXES Deferred income taxes result from differences between the timing of recognizing revenues and expenses for financial book purposes versus income tax purposes. The nature of the temporary differences and the resulting net deferred tax asset/liability for the two years ended December 31 follows:
| 2021 |  | 2020
Gross deferred tax assets: |  |  |
Pension, postretirement and other employee benefits | $597 |  |  | $1,403 |
New Zealand subsidiary | 21,790 |  |  | 23,461 |
CBPC tax credit carry forwards | 13,701 |  |  | 14,555 |
Capitalized real estate costs | 1,656 |  |  | 1,459 |
U.S. TRS net operating loss | 12,489 |  |  | 18,363 |
Land basis difference | 9,061 |  |  | 9,468 |
Other | 5,367 |  |  | 5,502 |
Total gross deferred tax assets | 64,661 |  |  | 74,211 |
Less: Valuation allowance | (36,904) |  |  | (46,015) |
Total deferred tax assets after valuation allowance | $27,757 |  |  | $28,196 |
Gross deferred tax liabilities: |  |  |
Accelerated depreciation | (46) |  |  | (38) |
New Zealand subsidiary | (91,388) |  |  | (98,245) |
Other | (6,059) |  |  | (4,884) |
Total gross deferred tax liabilities | (97,493) |  |  | (103,167) |
Net deferred tax liability reported as noncurrent | ($69,736) |  |  | ($74,971) |
Net operating loss (“NOL”) and tax credit carryforwards as of the two years ended December 31 follows:
| Tax Effected Balance |  |  |  |  | Expiration
2021 |  |  |  |  |  |
U.S. Federal NOL Carryforwards- Post TCJA (a) | $10,687 |  |  |  |  |  | None
U.S State NOL Carryforwards (b) | 1,802 |  |  |  |  |  | 2033
Cellulosic Biofuel Producer Credit (c) | 13,701 |  |  |  |  |  | 2023
2020 |  |  |  |  |  |
U.S. Federal NOL Carryforwards- Pre TCJA (a) | $2,363 |  |  |  |  |  | 2036
U.S. Federal NOL Carryforwards- Post TCJA (a) | 13,017 |  |  |  |  |  | None
U.S State NOL Carryforwards (b) | 2,983 |  |  |  |  |  | 2031
Cellulosic Biofuel Producer Credit (c) | 14,555 |  |  |  |  |  | 2023
(a)The Tax Cuts and Jobs Act (TCJA) was signed into law on December 22, 2017. The TCJA lifted the 20-year federal NOL Carryforward period. Net operating losses generated after December 31, 2017 have an indefinite carryforward period. (b)The U.S. state NOL is made up of several jurisdictions that expire in various future years. As of December 31, 2021, no state NOL is set to expire before December 31, 2033. As of December 31, 2020, no state NOL was set to expire before December 31, 2031. (c)The Further Consolidated Appropriations Act, 2020 was signed into law on December 20, 2019. The Further Consolidated Appropriations Act, 2020 included the Taxpayer Certainty and Disaster Relief Act of 2019 (Tax Extenders Act), which temporarily renewed approximately two dozen credits that previously expired or were set to expire at the end of 2019. The Cellulosic Biofuel Producer Credit was one of the credits extended under this act. We record a valuation allowance to reduce the carrying amounts of deferred tax assets if it is more likely than not that such deferred tax assets will not be realized. Since 2015, we have had a 100% valuation allowance against the U.S. taxable REIT subsidiary's deferred tax assets, net of deferred tax liabilities. During 2021, the net deferred tax assets decreased by $9.1 million. As a result, we recorded a change in the valuation allowance of $9.1 million related to the U.S. TRS's deferred tax assets, net of liabilities. TAX STATUTES The following table provides detail of the tax years that remain open to examination by the IRS and other significant taxing jurisdictions:
Taxing Jurisdiction | Open Tax Years
U.S. Internal Revenue Service | 2018 - 2020
New Zealand Inland Revenue | 2016 - 2020
TAX CHARACTERISTICS OF DIVIDEND DISTRIBUTIONS The taxable nature of the dividend distributions paid for each of the three years ended December 31 follows:
| 2021 |  | 2020 |  | 2019 |
Total dividends/distributions paid per common share/unit | $1.08 |  |  | $1.08 |  |  | $1.08 |  |
Tax characteristics: |  |  |  |  |  |
Capital gain | 100 | % |  | 100 | % |  | 100 | % |

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