NOTE 9 INCOME TAXES

The tax effects of temporary differences that give rise to significant portions of the deferred tax assets and deferred tax liabilities at December 31, 2014 and 2013 respectively are presented below:

	2014			2013
	(in thousands)
Deferred tax assets:
Alternative minimum tax (AMT) credit carryforward	$	41		$	41
Net operating loss carryforward		108,070			98,734
Mineral properties		14,797			19,884
Other temporary differences		6,859			6,302
Capital loss carryforward		241			241

Total gross deferred tax assets		130,008			125,202
Less: valuation allowance		(129,794	)		(125,202	)

Net deferred tax assets	$	214		$	—

Deferred tax liabilities:
Investments		(214	)		—
Acquired mineral property interests		(51,899	)		(158,855	)

Total deferred tax liabilities	$	(52,113	)	$	(158,855	)

Total net deferred tax liability	$	(51,899	)	$	(158,855	)

At December 31, 2014 and 2013, the Company estimates tax loss carry forwards to be $330.2 million and $303.3 million, respectively expiring starting in 2015 and going through 2034.

The Company believes that it is unlikely that the full amount of deferred tax assets will be realized. Therefore, a valuation allowance has been provided for most of the full amount of deferred tax assets. The change in valuation allowance of approximately $4.5 million (2013—$34.7 million) primarily reflects an increase of net operating loss carryforwards. The deferred tax liability related to the Minera Andes acquisition was $26.6 million as at December 31, 2014 (2013—$101.5 million).

On December 11, 2013, the Mexican government enacted a tax reform that increased the effective tax rate applicable to the Company's Mexican operations. The law, effective January 1, 2014, increased the future corporate income tax rate to 30%, created a 10% withholding tax on dividends paid to non-resident shareholders and created a new Extraordinary Mining duty which is equal to 0.5% of gross revenues from the sale of gold, silver and platinum. Furthermore, the reform introduced a Special Mining Duty of 7.5%. The Special Mining Duty is deductible for income tax purposes. The Special Mining Duty is generally applicable to earnings before income tax, depreciation, depletion, amortization and interest. There will be no deductions related to development type costs but exploration and prospecting costs are deductible when incurred. Certain undeducted exploration expenditures incurred prior to January 1, 2014 are also deductible in the calculation of the Special Mining Duty. For the year ended December 31, 2014, the Company had no taxes payable under the 7.5% Special Mining Duty, but accrued $0.2 million under the 0.5% gross revenue surcharge.

A reconciliation of the tax provision for 2014, 2013 and 2012 at statutory U.S. Federal and State income tax rates to the actual tax provision recorded in the financial statements is comprised of the following components:

Expected tax recovery at	2014			2013			2012
	(in thousands)
US Federal and State tax recovery at statutory rate	$	(142,499	)	$	(68,377	)	$	(31,925	)
Reconciling items:
Equity pickup in MSC		1,849			(2,924	)		(7,292	)
Impact of Mexican tax reform		754			(1,921	)		—
Prior year true ups/acquisitions		8,330			(19,016	)		781
Adjustment for foreign tax rates		(2,557	)		8,680			3,245
Tax rate changes		—			(187	)		(1,869	)
Imputed interest		198			171			135
Other permanent differences		(7,552	)		22,090			(3,259	)
Unrealized foreign exchange rate (loss)/gain		19,447			(28,317	)		(21,263	)
NOL expired		10,268			1,711			(2,696	)
Valuation allowance		4,592			34,725			36,899

Tax Recovery	$	(107,170	)	$	(53,365	)	$	(27,244	)

As at December 31, 2014, there are no unrecognized tax benefits. The entire income tax benefit, with the exception of $0.2 million allocated to other comprehensive income for the Company's investment in marketable securities, relates to continuing operations.

The Company or its subsidiaries file income tax returns in Canada, the United States, Mexico, and Argentina. These tax returns are subject to examination by local taxation authorities provided the tax years remain open to audit under the relevant statute of limitations. The following summarizes the open tax years by major jurisdiction:

United States: 2011 to 2014
Canada: 2007 to 2014
Mexico: 2010 to 2014
Argentina: 2010 to 2014