Income Taxes

The components of income tax expense were:



	2015			2014		2013
Current:
Federal	$	3,723		50		(525	)
State	3,924			(1,146	)	3,093
Deferred:
Federal	16,109			28,493		11,743
State	(484		)	(2,426	)	(176	)
	$	23,272		24,971		14,135

The following table reconciles income tax expense to the amount computed by applying the federal statutory rate to income before income taxes of $61,154, $76,777 and $36,519 in 2015, 2014 and 2013:



	2015			2014		2013
“Expected” federal income tax	$	21,404		26,872		12,782
Increase (decrease) in taxes attributable to:
State taxes, net of federal income tax benefit	3,332			4,155		1,836
Dividend received deduction	(43		)	(46	)	(60	)
Uncertain tax positions	3			—		(650	)
Sales & Use Enterprise Zone Credit	—			(880	)	—
Tangible Property Regulations	(1,081		)	(5,127	)	—
Other items, net	(343		)	(3	)	227
	$	23,272		24,971		14,135

The components of the net deferred tax liability as of December 31 was as follows:



	2015		2014
Deferred tax assets:
Advances and contributions	$	16,612	16,212
Unamortized investment tax credit	676		709
Pensions and postretirement benefits	4,094		4,216
California franchise tax	1,322		—
Net operating loss	—		5,065
Other	3,410		1,697
Total deferred tax assets	$	26,114	27,899
Deferred tax liabilities:
Utility plant	$	165,293	150,662
Pension and postretirement benefits	44,482		47,059
Investment in stock	2,193		2,335
Deferred gain and other-property related	11,686		11,695
Debt reacquisition costs	397		443
Other	838		1,211
Total deferred tax liabilities	$	224,889	213,405
Net deferred tax liabilities	$	198,775	185,506

Management evaluates the realizability of deferred tax assets based on all available evidence, both positive and negative. The realization of deferred tax assets is dependent on our ability to generate sufficient future taxable income during periods in which the deferred tax assets are expected to reverse. Based on all available evidence, management believes it is more likely than not that SJW Corp. will realize the benefits of these deferred tax assets.

As of December 31, 2015, the Company has estimated that it will utilize the entire federal net operating loss carry forward of $15,854 and state net operating loss carryforward of $1,525 to offset taxable income generated in 2015.

The total amount of unrecognized tax benefits, before the impact of deductions for state taxes, excluding interest and penalties was $795 and $684 as of December 31, 2015 and 2014, respectively. The amount of tax benefits, net of any federal benefits for state taxes and inclusive of interest that would impact the effective rate, if recognized, is approximately $17 and $14 as of December 31, 2015 and 2014, respectively.

A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows:



Balance at December 31, 2014	$	649
Increase related to tax positions taken during a prior year, including interest	106
Reductions related to tax positions taken in a prior year, including interest	—
Balance at December 31, 2015	$	755

SJW Corp.'s policy is to classify interest and penalties associated with unrecognized tax benefits, if any, in tax expense. Accrued interest expense, net of the benefit of tax deductions which would be available on the payment of such interest, is approximately $17 as of December 31, 2015. SJW Corp. has not accrued any penalties for unrecognized tax benefits. The amount of interest recognized in 2015 was an expense of $3.

SJW Corp. does not foresee material changes to its gross uncertain tax liability due to the lapse of the statute of limitations within the next 12 months following December 31, 2015.

In the second quarter of 2014, SJW Corp. recorded $880 in State of California enterprise zone sales and use tax credits related to tax years 2008 through 2012. SJW Corp. is currently undergoing an income tax examination by The California Franchise Tax Board for refund claims for fiscal years 2008 through 2012.

SJW Corp. applied for the accounting method changes required to comply with the Tangible Property Regulations with its 2014 tax returns. As of December 31, 2015, the 2015 federal and state repairs and maintenance deduction under the new methodology was $18,820, resulting in an estimated $6,587 federal deferred tax liability and a state income tax benefit of $1,081.

On September 13, 2013, the Department of Treasury and the Internal Revenue Service issued final tangible property regulations under provisions that generally are intended to simplify, clarify and make more administrable the 2011 temporary and proposed tangible property regulations. These regulations broadly apply to amounts to acquire, produce or improve tangible property, as well as dispositions of such property and provide criteria for determining whether such amounts can be deducted or should be capitalized as part of the asset. The final regulations generally are effective for tax years beginning on or after January 1, 2014. During the third quarter of 2014, management completed its evaluation of the capitalization elections under the new regulations in order to establish their method of complying with the new regulations and record the impact in the consolidated financial statements. To comply with the new regulations, SJW Corp. applied the accounting method change in the 2014 tax returns for the expensing of certain utility asset improvement costs for tax purposes as of December 31, 2013 that were previously being capitalized for book and tax purposes. As of December 31, 2014, the 2014 federal and state repairs and maintenance deduction under the new methodology was $11,221, resulting in an estimated $3,927 federal deferred tax liability and a state income tax benefit of $645. During the year ended December 31, 2014, SJW Corp. also completed a detailed analysis of the repairs and maintenance deduction related to 2013 and prior years, and recorded the estimated federal and state impact in the consolidated financial statements as of December 31, 2014. SJW Corp.'s Internal Revenue Code (“IRC”) §481(a) adjustment for Federal purposes was $35,912 and resulted in a $12,569 deferred tax liability as of December 31, 2014. SJW Corp.'s IRC §481(a) adjustment for state purposes was $77,999 and resulted in a $4,482 reduction to state income tax expense for the year ended December 31, 2014.

SJW Corp. files U.S. federal income tax returns and income tax returns in various states. The Company is no longer subject to tax examination for fiscal years prior to 2012 for federal purposes and 2010 for state purposes. The open tax years for the jurisdictions in which SJW Corp. files are as follows:



Jurisdiction	Years Open
Federal	2012 - 2014
California	2010 - 2014
Arizona	2011 - 2014
Connecticut	2012 - 2014
Florida	2012
Tennessee	2012 - 2014
Texas	2011 - 2014