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Income Taxes
12 Months Ended
Dec. 31, 2021
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
Prior to the Merger Transactions, we were organized as Delaware limited liability companies and Delaware limited partnerships and were treated as flow-through entities for U.S. federal income tax purposes. As a result, our tax provisions for the years ended December 31, 2020 and 2019 were minimal. Subsequent to the Merger Transactions we are subject to U.S. federal income and state tax on our allocable share of any taxable income of OpCo. Details of income tax provisions and deferred income taxes are provided in the following tables:

Year Ended December 31,
202120202019
Federal income tax provision (benefit)(in thousands)
Current
$— $— $— 
Deferred(935)— — 
State income tax provision (benefit)
Current
629 14 28 
Deferred— — — 
Total income tax provision (benefit)$(306)$14 $28 

The difference between the statutory federal income tax rate and the Company's effective income tax rate is explained as follows:
Year Ended December 31,
202120202019
Federal income taxes statutory rate21.0 %— %— %
Increase (decrease) in rate as a result of:
State current income tax provision, net of federal benefit(0.1)%— %— %
Permanent adjustments (1)
(1.7)%— %— %
Income attributable to Predecessor that was not subject to corporate income tax (2)
(18.4)%— %— %
Income attributable to noncontrolling interests(0.7)%— %— %
Effective income tax rate0.1 %— %— %
(1)During the year ended December 31, 2021, the permanent items primarily related to disallowed officer compensation under Section 162(m) of the Internal Revenue Code.
(2)    During the year ended December 31, 2021, the income attributable to Predecessor was not subject to corporate income tax as we were organized as limited liability companies and limited partnerships that were treated as flow-through entities for U.S federal income tax purposes prior to the Merger Transactions.

Significant components of the Company's deferred income taxes were as follows:
Year Ended December 31,
20212020
Deferred tax liabilities(in thousands)
Outside Basis in OpCo$98,079 $— 
Deferred tax assets
Federal and state NOL (1)
38,317 — 
Federal and state NOL valuation allowance(30,567)— 
Recognized built-in loss carryforward6,872 — 
Other920 — 
Total deferred tax assets, net of valuation allowance15,542 — 
Net deferred income tax liability$82,537 $— 
(1)We have Federal NOLs of $1.9 million, net of tax, that have expiration dates beginning in 2026. We also have NOLs of $36.4 million, net of tax, that were generated after 2017 and have indefinite lives but are limited to offsetting 80% of taxable income in a given tax year.

We assess the available positive and negative evidence to determine if sufficient future taxable income will be generated to use the existing deferred tax assets. On the basis of this evaluation, as of December 31, 2021, a valuation allowance has been recorded to recognize only the portion of the deferred tax assets that are more likely than not to be realized. The amount of the deferred tax asset considered realizable, however, could be adjusted in the future.

As part of the Merger Transactions, we acquired the federal and state NOLs subject to a valuation allowance of $30.6 million due to the Section 382 limitation. During the year ended December 31, 2021, after the Merger Transactions, we recorded an additional valuation allowance related to additional state NOLs incurred that we do not believe are recoverable.

Pursuant to Sections 382 and 383 of the Internal Revenue Code, utilization of our NOLs and credits is subject to a small annual limitation. These annual limitations may result in the expiration of NOLs and credits prior to utilization.
As of December 31, 2021 and 2020, we did not have any uncertain tax positions.