Income Taxes

The components of income tax expense were:



	2016			2015		2014
Current:
Federal	$	21,651		3,723		50
State	7,088			3,924		(1,146	)
Deferred:
Federal	6,119			16,109		28,493
State	(1,316		)	(484	)	(2,426	)
	$	33,542		23,272		24,971

The following table reconciles income tax expense to the amount computed by applying the federal statutory rate to income before income taxes of $86,381, $61,154 and $76,777 in 2016, 2015 and 2014:



	2016			2015		2014
“Expected” federal income tax	$	30,233		21,404		26,872
Increase (decrease) in taxes attributable to:
State taxes, net of federal income tax benefit	4,874			3,332		4,155
Dividend received deduction	(21		)	(43	)	(46	)
Uncertain tax positions	16			3		—
Sales & Use Enterprise Zone Credit	(117		)	—		(880	)
Tangible Property Regulations	(1,184		)	(1,081	)	(5,127	)
Other items, net	(259		)	(343	)	(3	)
	$	33,542		23,272		24,971

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



	2016		2015
Deferred tax assets:
Advances and contributions	$	17,196	16,612
Unamortized investment tax credit	644		676
Pensions and postretirement benefits	3,927		4,094
California franchise tax	2,331		1,322
Other	4,802		3,410
Total deferred tax assets	$	28,900	26,114
Deferred tax liabilities:
Utility plant	$	177,338	165,293
Pension and postretirement benefits	44,737		44,482
Investment in stock	1,280		2,193
Deferred gain and other-property related	9,769		11,686
Debt reacquisition costs	347		397
Other	632		838
Total deferred tax liabilities	$	234,103	224,889
Net deferred tax liabilities	$	205,203	198,775

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 Group will realize the benefits of these deferred tax assets.

The total amount of unrecognized tax benefits, before the impact of deductions for state taxes, excluding interest and penalties was $1,184 and $795 as of December 31, 2016 and 2015, 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 $33 and $17 as of December 31, 2016 and 2015, respectively.

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



Balance at December 31, 2015	$	755
Increase related to tax positions taken during a prior year, including interest	397
Reductions related to tax positions taken in a prior year, including interest	(20		)
Balance at December 31, 2016	$	1,132

SJW Group’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 $33 as of December 31, 2016. SJW Group has not accrued any penalties for unrecognized tax benefits. The amount of interest recognized in 2016 was an expense of $16.

SJW Group 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, 2016.

In the fourth quarter of 2016, SJW Group recorded $117 in State of California enterprise zone sales and use tax credits related to tax years 2013 and 2014. In the second quarter of 2014, SJW Group had recorded $880 in State of California enterprise zone sales and use tax credits related to tax years 2008 through 2012. SJW Group is currently undergoing an income tax examination by The California Franchise Tax Board for refund claims for fiscal years 2008 through 2012.

SJW Group applied for the accounting method changes required to comply with the Tangible Property Regulations with the 2014 tax returns. As of December 31, 2016, the 2016 federal and state repairs and maintenance deduction under the new methodology was $20,611, resulting in an estimated $7,214 federal deferred tax liability and a state income tax benefit of $1,184.

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. 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. To comply with the new regulations, SJW Group 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 Group 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 Group’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 Group’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 Group 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 2013 for federal purposes and 2010 for state purposes. The open tax years for the jurisdictions in which SJW Group files are as follows:



Jurisdiction	Years Open
Federal	2013 - 2015
California	2010 - 2015
Arizona	2012 - 2015
Connecticut	2013 - 2014
Tennessee	2013 - 2015
Texas	2012 - 2015