XML 49 R29.htm IDEA: XBRL DOCUMENT v3.25.0.1
INCOME TAXES
 12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
INCOME TAXES INCOME TAXES
PBF Energy is required to file federal and applicable state corporate income tax returns and recognizes income taxes on its pre-tax income, which to-date has consisted primarily of its share of PBF LLC’s pre-tax income (see “Note 13 - Stockholders’ and Members’ Equity Structure”). PBF LLC is organized as a limited liability company and PBFX is a 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 the two subsidiaries acquired in connection with the acquisition of Chalmette Refining and PBF Holding’s wholly-owned Canadian subsidiary, PBF Energy Limited, that are treated as C-Corporations for income tax purposes, with the tax provision calculated based on the effective tax rate for the periods presented.
Valuation Allowance
The Company assesses the available positive and negative evidence to estimate whether sufficient future taxable income will be generated to permit use of existing deferred tax assets. Negative evidence evaluated as part of this assessment includes cumulative losses incurred over a three-year period. Such objective evidence could limit PBF Energy’s ability to consider other subjective evidence, such as PBF Energy’s projections for future taxable income as market conditions, commodity prices and demand for refined products normalize.
On the basis of this evaluation, a valuation allowance is recorded to recognize only the portion of deferred tax assets that are more likely than not to be realized. The amount of the deferred tax assets considered realizable, however, could be adjusted if estimates of future taxable income during the carryover period are reduced or increased or if objective negative evidence in the form of cumulative losses is no longer present and additional weight is given to subjective evidence such as PBF Energy’s projections for future taxable income.
During the year ended December 31, 2022, the Company evaluated all available positive and negative evidence and determined that the $308.5 million valuation allowance, as of December 31, 2021, associated with deferred tax assets should be released because the Company believed that it had become more likely than not that the deferred tax assets would be realized. In the Company' s evaluation of the need for and amount of a valuation allowance on its deferred tax assets, the Company placed the most weight on objectively verifiable direct evidence, including its recent and historical operating results and the significant improvement in its operating profitability. The specific positive factors and evidence considered in the realizability of its deferred tax assets included the cumulative pre-tax income that the Company generated over the past three-year period. This resulted in the release of the full valuation allowance in the year ended December 31, 2022.
Inflation Reduction Act
On August 16, 2022, the Inflation Reduction Act (“IRA”) was enacted and signed into law in the United States. The IRA is a budget reconciliation package that includes significant law changes relating to tax, climate change, energy, and health care. The tax provisions include, among other items, a corporate alternative minimum tax of 15%, an excise tax of 1% on corporate stock buy-backs, energy-related tax credits and incentives, and additional IRS funding. Based on the Company’s results over the past three fiscal years, the corporate alternative minimum tax would be applicable but is currently not expected to have a material impact on the Company’s Consolidated Financial Statements. The Company does not expect the other tax provisions of the IRA to have a material impact on its Consolidated Financial Statements.
The income tax provision in the PBF Energy Consolidated Statements of Operations consists of the following:
Year Ended December 31,
(in millions)202420232022
Current (benefit) expense:
Federal$(10.6)$140.9 $75.8 
Foreign— (0.3)0.3 
State21.4 46.2 88.5 
Total current10.8 186.8 164.6 
  
Deferred (benefit) expense:
Federal(156.6)387.7 379.9 
Foreign(4.8)3.1 (0.9)
State(77.8)146.2 41.2 
Total deferred(239.2)537.0 420.2 
Total provision for income taxes$(228.4)$723.8 $584.8 
The difference between PBF Energy’s effective income tax rate and the United States statutory rate is reconciled below:
Year Ended December 31,
202420232022
Provision at Federal statutory rate21.0 %21.0  %21.0 %
Increase (decrease) attributable to flow-through of certain tax adjustments:
State income taxes (net of federal income tax)5.0 %5.0 %4.9 %
Nondeductible/nontaxable items3.3 %(0.5)%(0.4)%
Rate differential from foreign jurisdictions (0.2)%— %— %
Provision to return adjustment0.2 %(0.1)%— %
Adjustment to deferred tax assets and liabilities for change in tax rates— %— %(0.2)%
Deferred tax asset valuation allowance — %— %(8.9)%
Other0.7 %(0.1)%0.5 %
Effective tax rate30.0 %25.3 %16.9 %
PBF Energy’s effective income tax rate for the years ended December 31, 2024, 2023 and 2022, including the impact of income (loss) attributable to noncontrolling interests of $(6.4) million, $21.5 million and $96.0 million, respectively, was 29.7%, 25.1% and 16.4%, respectively.
For the year ended December 31, 2024, PBF Energy’s effective tax rate differed from the United States statutory rate, inclusive of state income taxes, as a result of equity-based compensation activity and permanent book/tax differences related to the use of blender’s tax credits.
For the year ended December 31, 2023, PBF Energy’s effective tax rate did not materially differ from the United States statutory rate, inclusive of state income taxes. For the year ended December 31, 2022, PBF Energy’s effective tax rate differed from the United States statutory rate, inclusive of state income taxes, primarily due to changes in the deferred tax asset valuation allowance.
For financial reporting purposes, income (loss) before income taxes attributable to PBF Energy Inc. stockholders includes the following components:
Year Ended December 31,
(in millions)202420232022
United States income (loss)$(739.8)$2,852.4 $3,464.2 
Foreign income (loss)(22.4)11.9 (2.6)
Total income (loss) before income taxes attributable to PBF Energy Inc. stockholders$(762.2)$2,864.3 $3,461.6 
A summary of the components of PBF Energy’s deferred tax assets and deferred tax liabilities consists of the following: 
(in millions)December 31, 2024December 31, 2023
Deferred tax assets
Purchase interest step-up$165.0 $171.6 
Pension, employee benefits and compensation53.3 96.5 
Net operating loss carry forwards297.5 3.4 
Environmental liabilities39.0 40.4 
Lease liabilities 317.4 305.9 
Other50.7 27.0 
Total deferred tax assets922.9 644.8 
 
Deferred tax liabilities
Property, plant and equipment1,122.0 1,062.2 
Inventory60.3 68.6 
Right of use assets314.5 303.5 
Equity method investment in SBR 249.6 278.8 
Other12.5 5.0 
Total deferred tax liabilities1,758.9 1,718.1 
Net deferred tax liability$(836.0)$(1,073.3)
As of December 31, 2024, PBF Energy had $1,088.0 million of gross federal and $69.0 million of net state income tax operating loss carry forwards. The portion of the federal net operating loss carry forward that was generated in years prior to 2019 was utilized in 2022. The federal net operating loss carry forward was generated in 2024 and it has an indefinite carryforward period but is limited to 80% of taxable income in each tax year. The state net operating loss carry forwards expire at various dates from 2028 through 2044 with certain jurisdictions having indefinite net operating loss carry forward periods.
Income tax years that remain subject to examination by material jurisdictions, where an examination has not already concluded are all years including and subsequent to:
United States
Federal2020
New Jersey2020
Michigan2020
Delaware2021
Indiana2021
Pennsylvania2021
New York2021
Louisiana2021
California2020
The Company does not have any unrecognized tax benefits.