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Income Taxes | 12 Months Ended
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Dec. 31, 2023
Income Taxes [Abstract] |
Income Taxes | 22. Income Taxes Income before Income Tax Expense – Domestic and Foreign The U.S. and foreign components of income before income tax expense for the years ended December 31, 2023, 2022 and 2021 are as follows:
|  | Year Ended December 31,
|  | 2023 |  | 2022 |  | 2021
U.S. |  | $ | 4,652 |  | $ | (4,067) |  | $ | 15,986
Foreign |  |  | 114,356 |  |  | 44,017 |  |  | 40,685
Total |  | $ | 119,008 |  | $ | 39,950 |  | $ | 56,671
Income Tax Expense/(Benefit) – By Jurisdiction The components of current and deferred income tax expense included in the Consolidated Statement of Operations for years ended December 31, 2023, 2022 and 2021 are as follows:
|  | Years Ended December 31,
|  | 2023 |  | 2022 |  | 2021
Current: |  |  |  |  |  |
Federal |  | $ | 6,957 |  | $ | 4,685 |  | $ | 5,857
State and local |  |  | 1,883 |  |  | 1,415 |  |  | 1,538
Foreign |  |  | 8,103 |  |  | (15,538) |  |  | (837)
|  | $ | 16,943 |  | $ | (9,438) |  | $ | 6,558
Deferred: |  |  |  |  |  |  |  |  |
Federal |  | $ | (494) |  | $ | (6) |  | $ | (1,217)
State and local |  |  | (102) |  |  | (1) |  |  | (251)
Foreign |  |  | 115 |  |  | (1,289) |  |  | 1,784
|  | $ | (481) |  | $ | (1,296) |  | $ | 316
Income tax expense/(benefit) |  | $ | 16,462 |  | $ | (10,734) |  | $ | 6,874
Reconciliation of Statutory Federal Income Tax Rate to the Effective Income Tax Rate A reconciliation of the statutory federal income tax expense and the Company’s total income tax expense is as follows:
|  | Years Ended December 31,
|  | 2023 |  | 2022 |  | 2021
U.S. federal statutory income tax |  | $ | 24,992 |  | $ | 8,386 |  | $ | 11,901
Gain on revaluation/termination of deferred consideration(1) |  |  | (13,007) |  |  | (5,842) |  |  | (424)
Non-deductible loss on extinguishment of convertible notes |  |  | 2,263 |  |  | — |  |  | —
Foreign operations |  |  | (1,868) |  |  | (2,919) |  |  | (3,211)
Non-deductible executive compensation |  |  | 1,833 |  |  | 789 |  |  | 881
Decrease in unrecognized tax benefits, net |  |  | (1,386) |  |  | (19,871) |  |  | (4,998)
Change in valuation allowance – Capital losses |  |  | 1,340 |  |  | 4,761 |  |  | 5
Expiration of capital losses |  |  | 796 |  |  | — |  |  | —
Stock-based compensation tax shortfalls |  |  | 373 |  |  | 507 |  |  | 647
Change in tax-related indemnification assets, net |  |  | 291 |  |  | 4,173 |  |  | 1,053
Change in foreign net operating losses (“NOLs”) |  |  | 174 |  |  | — |  |  | —
Blended state income tax rate, net of federal benefit |  |  | 153 |  |  | (134) |  |  | 526
Change in valuation allowance—Foreign NOLs and interest carryforwards |  |  | — |  |  | (1,609) |  |  | —
GILTI |  |  | — |  |  | 499 |  |  | —
Other differences, net |  |  | 508 |  |  | 526 |  |  | 494
Income tax expense/(benefit) |  | $ | 16,462 |  | $ | (10,734) |  | $ | 6,874
​(1) The gain on revaluation of deferred consideration is not adjusted for income taxes as the obligation was assumed by a wholly-owned subsidiary that is based in Jersey, a jurisdiction where the Company is subject to a zero percent tax rate. Income Tax Payments A summary of income taxes paid by jurisdiction for the years ended December 31, 2023, 2022 and 2021 is as follows:
|  | Years Ended December 31,
|  | 2023 |  | 2022 |  | 2021
Federal |  | $ | 4,824 |  | $ | 6,424 |  | $ | 4,258
State and local |  |  | 1,457 |  |  | 1,431 |  |  | 1,020
Foreign |  |  | 9,875 |  |  | 4,645 |  |  | 3,178
|  | $ | 16,156 |  | $ | 12,500 |  | $ | 8,456
Deferred Tax Assets A summary of the components of the Company’s deferred tax assets at December 31, 2023 and 2022 is as follows:
|  | 2023 |  | 2022
Deferred tax assets: |  |  |  |
Capital losses |  | $ | 22,489 |  | $ | 17,541
Accrued expenses |  |  | 6,000 |  |  | 6,030
Stock-based compensation |  |  | 2,468 |  |  | 1,526
NOLs—Foreign |  |  | 1,502 |  |  | 1,609
Goodwill and intangible assets |  |  | 895 |  |  | 1,085
Unrealized losses |  |  | 335 |  |  | 3,821
Foreign currency translation adjustment |  |  | 146 |  |  | 173
NOLs—U.S. |  |  | 127 |  |  | 255
Operating lease liabilities |  |  | 96 |  |  | 313
Outside basis differences |  |  | — |  |  | 122
Other |  |  | 401 |  |  | 341
Deferred tax assets |  |  | 34,459 |  |  | 32,816
Deferred tax liabilities: |  |  |  |  |  |
Fixed assets and prepaid assets |  |  | 296 |  |  | 278
Unremitted earnings—European subsidiaries |  |  | 186 |  |  | 205
Right of use assets—operating leases |  |  | 96 |  |  | 313
Deferred tax liabilities |  |  | 578 |  |  | 796
Total deferred tax assets less deferred tax liabilities |  |  | 33,881 |  |  | 32,020
Less: Valuation allowance |  |  | (22,824) |  |  | (21,484)
Deferred tax assets, net |  | $ | 11,057 |  | $ | 10,536
Net Operating and Capital Losses – U.S. The Company’s tax effected NOLs at December 31, 2023 were $127, which expire in 2024. The net operating loss carryforwards have been reduced by the impact of annual limitations described in the Internal Revenue Code Section 382 that arose as a result of an ownership change. The Company’s tax effected capital losses at December 31, 2023 were $22,489. These capital losses expire between the years 2024 and 2028. During the year ended December 31, 2023, tax effected capital losses in the amount of $3,278 expired. Net Operating Losses – Europe One of the Company’s European subsidiaries generated NOLs outside the U.S. These tax effected NOLs, all of which are carried forward indefinitely, were $1,502 at December 31, 2023. Valuation Allowance The Company’s valuation allowance has been established on its net capital losses, unrealized losses and outside basis differences, as it is more-likely-than-not that these deferred tax assets will not be realized. During the year ended December 31, 2022, the Company released the valuation allowance on its European net operating losses of $1,609 as it is more-likely-than-not that these deferred tax assets will be realized. Uncertain Tax Positions Tax positions are evaluated utilizing a two-step process. The Company first determines whether any of its tax positions are more-likely-than-not to be sustained upon examination, based solely on the technical merits of the position. Once it is determined that a position meets this recognition threshold, the position is measured as the largest amount of benefit that is greater than 50% likely of being realized upon ultimate settlement. In connection with the ETFS Acquisition, the Company accrued a liability for uncertain tax positions and interest and penalties at the acquisition date. The Company also recorded an offsetting indemnification asset provided by ETFS Capital as part of its agreement to indemnify the Company for any potential claims. The table below sets forth the aggregate changes in the balance of these gross unrecognized tax benefits:
|  | Total |  | Unrecognized Tax Benefits |  | Interest and Penalties
Balance at January 1, 2022 |  | $ | 21,925 |  | $ | 18,218 |  | $ | 3,707
Decrease—Settlements(1) |  |  | (13,052) |  |  | (11,865) |  |  | (1,187)
Decrease—Lapse of statute of limitations(1) |  |  | (6,845) |  |  | (4,825) |  |  | (2,020)
Increases |  |  | 26 |  |  | — |  |  | 26
Foreign currency translation(2) |  |  | (701) |  |  | (571) |  |  | (130)
Balance at December 31, 2022 |  | $ | 1,353 |  | $ | 957 |  | $ | 396
Decrease—Lapse of statute of limitations |  |  | (1,353) |  |  | (957) |  |  | (396)
Balance at December 31, 2023 |  | $ | — |  | $ | — |  | $ | —
​(1) In January 2022, an audit of ManJer’s tax returns (a Jersey-based subsidiary) for the years ended December 31, 2014, 2016, 2017 and 2018 were resolved in favor of ManJer. The settlement, as well as the reduction in unrecognized tax benefits from the lapse of the statute of limitations totaling $19,897 during the year ended December 31, 2022 was recorded as an income tax benefit along with an equal and offsetting amount recorded in other losses and gains, net, to recognize a reduction in the indemnification asset. (2) The gross unrecognized tax benefits were accrued in British pounds. The gross unrecognized tax benefits and interest and penalties totaling $1,353 at December 31, 2022 is included in other non-current liabilities on the Consolidated Balance Sheets. Income Tax Examinations The Company is subject to U.S. federal income tax as well as income tax of multiple state, local and certain foreign jurisdictions. ManJer’s tax returns (a Jersey-based subsidiary) were previously under review for the years ended December 31, 2014, 2016, 2017 and 2018. In January 2022, the audit was resolved in favor of ManJer. In addition, the Company’s tax returns were previously under review by the State of Michigan for the years ended 2017 through 2020. In August 2022, the audit was resolved in favor of the Company. As of December 31, 2023, with few exceptions, the Company was no longer subject to income tax examinations by any taxing authority for the years before 2019. Undistributed Earnings of Foreign Subsidiaries ASC 740-30 Income Taxes provides guidance that U.S. companies do not need to recognize tax effects on foreign earnings that are indefinitely reinvested. The Company repatriates earnings of its foreign subsidiaries and therefore has recognized a deferred tax liability of $186 and $205 at December 31, 2023 and 2022, respectively.

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- Definition The entire disclosure for income taxes. Disclosures may include net deferred tax liability or asset recognized in an enterprise's statement of financial position, net change during the year in the total valuation allowance, approximate tax effect of each type of temporary difference and carryforward that gives rise to a significant portion of deferred tax liabilities and deferred tax assets, utilization of a tax carryback, and tax uncertainties information. + References Reference 1: http://www.xbrl.org/2003/role/disclosureRef -Topic 946 -SubTopic 20 -Name Accounting Standards Codification -Section 50 -Paragraph 13 -Publisher FASB -URI https://asc.fasb.org//1943274/2147480990/946-20-50-13 Reference 2: http://www.xbrl.org/2003/role/disclosureRef -Topic 235 -SubTopic 10 -Name Accounting Standards Codification -Section S99 -Paragraph 1 -Subparagraph (SX 210.4-08(h)(2)) -Publisher FASB -URI https://asc.fasb.org//1943274/2147480678/235-10-S99-1 Reference 3: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -Name Accounting Standards Codification -Publisher FASB -URI https://asc.fasb.org//740/tableOfContent Reference 4: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -SubTopic 10 -Name Accounting Standards Codification -Section 50 -Paragraph 14 -Publisher FASB -URI https://asc.fasb.org//1943274/2147482685/740-10-50-14 Reference 5: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -SubTopic 10 -Name Accounting Standards Codification -Section 50 -Paragraph 21 -Publisher FASB -URI https://asc.fasb.org//1943274/2147482685/740-10-50-21 Reference 6: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -SubTopic 270 -Name Accounting Standards Codification -Section 50 -Paragraph 1 -Publisher FASB -URI https://asc.fasb.org//1943274/2147482526/740-270-50-1 Reference 7: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -SubTopic 10 -Name Accounting Standards Codification -Section 50 -Paragraph 17 -Subparagraph (b) -Publisher FASB -URI https://asc.fasb.org//1943274/2147482685/740-10-50-17 Reference 8: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -SubTopic 10 -Name Accounting Standards Codification -Section S99 -Paragraph 1 -Subparagraph (SAB TOPIC 6.I.5.Q1) -Publisher FASB -URI https://asc.fasb.org//1943274/2147479360/740-10-S99-1 Reference 9: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -SubTopic 10 -Name Accounting Standards Codification -Section S99 -Paragraph 2 -Subparagraph (SAB Topic 11.C) -Publisher FASB -URI https://asc.fasb.org//1943274/2147479360/740-10-S99-2 Reference 10: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -SubTopic 30 -Name Accounting Standards Codification -Section 50 -Paragraph 2 -Subparagraph (a) -Publisher FASB -URI https://asc.fasb.org//1943274/2147482603/740-30-50-2 + Details
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