INCOME TAXES

PBF Energy files federal and applicable state corporate income tax returns and recognizes income taxes on its pre-tax income, which to date has consisted solely of its share of PBF LLC’s pre-tax income (approximately 95.1% as of December 31, 2015 and approximately 95.2% as of March 31, 2016). PBF LLC is organized as a limited liability company and PBFX is a master limited partnership, both of which are treated as “flow-through” entities for federal income tax purposes and therefore are not subject to income taxes apart from the income tax attributable to two subsidiaries of Chalmette Refining that are treated as C-Corporations for income tax purposes. As a result, PBF Energy's condensed consolidated financial statements do not reflect any benefit or provision for income taxes on the pre-tax income or loss attributable to the noncontrolling interests in PBF LLC or PBFX apart from the income tax of $799 for the three months ended March 31, 2016 attributable to those two C-Corporation subsidiaries of Chalmette Refining.

The income tax provision in the PBF Energy condensed consolidated financial statements of operations consisted of the following:



	Three Months Ended March 31,
	2016			2015
Current tax (benefit) expense	$	(75,454	)	$	25,970
Deferred tax expense	52,954			23,168
Total tax (benefit) expense	$	(22,500	)	$	49,138

Income tax expense (benefit) is based on income before taxes attributable to PBF Energy and excludes income before taxes attributable to noncontrolling interests as such interests are not subject to income taxes. The difference between the Company’s income tax expense (benefit) and the income tax provision computed by applying the United States statutory rate and the difference between the Company’s effective income tax rate and the United States statutory rate are reconciled below:



	Three Months Ended March 31, 2016					Three Months Ended March 31, 2015
Provision at Federal statutory rate	$	(18,161	)	35.0	%	$	47,689		35.0	%
Increase (decrease) attributable to flow-through of certain tax adjustments:
State income taxes (net federal income tax)	(2,402		)	4.6	%	7,098			5.2	%
Non deductible/nontaxable items	135			(0.3	)%	526			0.4	%
Adjustment for manufacturer's benefit	—			—	%	(1,206		)	(0.9	)%
Rate differential from foreign jurisdictions	(375		)	0.7	%	(5,629		)	(4.1	)%
Other	(1,697		)	3.3	%	660			0.5	%
Total	$	(22,500	)	43.3	%	$	49,138		36.1	%

The Company's effective income tax rate for the three months ended March 31, 2016 and 2015, including the impact of income attributable to noncontrolling interests of $6,052 and $15,798, respectively, was 49.1% and 32.3%, respectively.

PBF Energy has determined there are no material uncertain tax positions as of March 31, 2016. PBF Energy does not have any unrecognized tax benefits.