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Income Taxes
 9 Months Ended
Sep. 30, 2024
Income Tax Disclosure [Abstract]  
Income Taxes
Note 13. Income Taxes
The (benefit from) provision for income taxes was $(4.2) million and $(3.8) million for the three months ended September 30, 2024 and 2023, respectively, and $2.3 million and $6.3 million for the nine months ended September 30, 2024 and 2023, respectively.
Beginning in 2022, the U.S. Tax Cuts and Jobs Act (“Tax Act”) enacted on December 22, 2017 eliminated the option to deduct research and development expenditures for tax purposes in the period the expenses were incurred and instead requires all U.S. and foreign research and development expenditures to be amortized over five and fifteen tax years, respectively.
Due to this required capitalization of research and development expenditures, the Company has recorded current U.S. income tax expense of $1.9 million and $4.7 million for the three and nine months ended September 30, 2024. The current U.S. income tax provision is primarily for federal and state taxes currently payable that we anticipate paying as a result of statutory limitations on our ability to offset expected taxable income with net operating loss carry forwards.
The realization of tax benefits of net deferred tax assets is dependent upon future levels of taxable income, of an appropriate character, in the periods the items are expected to be deductible or taxable. Based on the available objective evidence, except with respect to the UK deferred tax assets described below, the Company does not believe it is more likely than not that certain net deferred tax assets will be realizable. Accordingly, the Company continues to provide a full valuation allowance against the entire domestic net deferred tax assets as of September 30, 2024 and December 31, 2023. The Company intends to maintain the full valuation allowance on the U.S. net deferred tax assets until sufficient positive evidence exists to support a reversal of, or decrease in, the valuation allowance.
On September 30, 2024, RingCentral UK Ltd (“RC UK”), a wholly-owned subsidiary of the Company, entered into a License Agreement and a Limited Risk Distributor Agreement with the Company, which resulted in the reclassification of RC UK from a Full Risk Distributor into a Limited Risk Distributor. The Company determined that it was more likely than not that the UK deferred tax assets were realizable. As a result, during the third quarter of 2024, the Company released the valuation allowance against the UK deferred tax assets and recorded a $4.6 million income tax benefit under (benefit from) provision for income taxes in the Condensed Consolidated Statement of Operations.
During the three and nine months ended September 30, 2024, there were no material changes to the total amount of unrecognized tax benefits.