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Income Taxes | 12 Months Ended
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Dec. 31, 2014
Income Taxes | (11) Income Taxes As of December 31, 2014 and 2013, interest and penalties related to any uncertain tax positions have been insignificant. The Company recognizes interest and penalties related to uncertain tax positions within the provision for income taxes. The total amount of unrecognized tax benefits that would affect the Company’s effective tax rate if recognized is $1.4 million as of December 31, 2014, as compared to $1.7 million as of December 31, 2013. The following is a reconciliation of the total amounts of unrecognized tax benefits for the years ended December 31, 2014, 2013 and 2012 (in thousands):
|  | 2014 |  |  | 2013 |  |  | 2012 |
Beginning uncertain tax benefits |  | $ | 1,674 |  |  | $ | 1,243 |  |  | $ | 997 |
Current year—increases |  |  | 1,067 |  |  |  | 687 |  |  |  | 294 |
Current year—decreases for lapses in statutes of limitations |  |  | (254 | ) |  |  | (256 | ) |  |  | (48 | )
Ending uncertain tax benefits |  | $ | 2,487 |  |  | $ | 1,674 |  |  | $ | 1,243 |
The Company files income tax returns in the U.S., Ireland and United Kingdom. The Company remains subject to tax examinations in the following jurisdictions as of December 31, 2014:
Jurisdiction |  | Tax Years |
United States (Federal and State) |  |  | 2011-2014 |
Ireland |  |  | 2009-2014 |
United Kingdom |  |  | 2013-2014 |
The Company expects gross liabilities of $439,000 to expire in 2015 based on statutory lapses. The components of loss from operations before taxes were as follows at December 31, 2014, 2013 and 2012 (in thousands):
|  | 2014 |  |  | 2013 |  |  | 2012 |
United States |  | $ | (7,331 | ) |  | $ | (9,234 | ) |  | $ | 1,874 |
Ireland and United Kingdom |  |  | (51,870 | ) |  |  | (160,187 | ) |  |  | (171,942 | )
|  | $ | (59,201 | ) |  | $ | (169,421 | ) |  | $ | (170,068 | )
The (benefit) expense from income taxes shown in the accompanying consolidated statements of operations consists of the following for fiscal 2014, 2013 and 2012 (in thousands):
|  | 2014 |  |  | 2013 |  |  | 2012 |
Current: |  |  |  |  |  |  |  |  |  |  |  |
Federal-U.S. |  | $ | 660 |  |  | $ | 122 |  |  | $ | 10,265 |
State-U.S. |  |  | 117 |  |  |  | 118 |  |  |  | 2,565 |
Total Current |  | $ | 777 |  |  | $ | 240 |  |  | $ | 12,830 |
Deferred: |  |  |  |  |  |  |  |  |  |  |  |
Federal-U.S. |  |  | (3,689 | ) |  |  | (4,065 | ) |  |  | (2,803 | )
State-U.S. |  |  | (226 | ) |  |  | 631 |  |  |  | (911 | )
Ireland and United Kingdom |  |  | 3,335 |  |  |  | (33,106 | ) |  |  | (22,515 | )
Change in valuation allowance |  |  | (3,034 | ) |  |  | 33,106 |  |  |  | 22,515 |
Total Deferred |  | $ | (3,614 | ) |  | $ | (3,434 | ) |  | $ | (3,714 | )
|  | $ | (2,837 | ) |  | $ | (3,194 | ) |  | $ | 9,116 |
The (benefit) expense from income taxes differs from the amount computed by applying the statutory income tax rate to income before taxes due to the following for fiscal 2014, 2013 and 2012 (in thousands):
|  | 2014 |  |  | 2013 |  |  | 2012 |
Benefits from taxes at statutory rate |  | $ | (14,786 | ) |  | $ | (42,355 | ) |  | $ | (42,517 | )
Rate differential |  |  | 9,493 |  |  |  | 18,494 |  |  |  | 13,249 |
Change in valuation reserves |  |  | (3,034 | ) |  |  | 33,106 |  |  |  | 22,515 |
Warrant derivative liabilities |  |  | (2,706 | ) |  |  | (11,984 | ) |  |  | 8,904 |
Gain on extinguishment of debt |  |  | (9,509 | ) |  |  | — |  |  |  | — |
Research and development credits |  |  | (1,455 | ) |  |  | (2,008 | ) |  |  | (48 | )
Tax return to provision adjustments |  |  | 10,026 |  |  |  | 125 |  |  |  | 375 |
Cumulative translation adjustment |  |  | 8,061 |  |  |  | (280 | ) |  |  | — |
Permanent and other |  |  | 1,073 |  |  |  | 1,708 |  |  |  | 6,638 |
|  | $ | (2,837 | ) |  | $ | (3,194 | ) |  | $ | 9,116 |
During 2014, the Company recorded adjustments to its deferred tax accounts related to the impact of foreign exchange rate changes and to reconcile the financial statement accounts to the amounts reported on its filed 2013 foreign tax returns, primarily for the impact of US GAAP to local statutory adjustments. These adjustments were fully offset with valuation allowances based on the Company’s position with respect to the realizability of its recorded deferred tax assets for non-US entities. The Company is subject to corporate tax rate in Ireland of 25% for non-trading activities and 12.5% for trading activities. For the years ended December 31, 2014, 2013 and 2012, the Company applied the statutory corporate tax rate of 25% for Amarin Corporation plc, reflecting the non-trading tax rate in Ireland. However, for Amarin Pharmaceuticals Ireland Limited, a wholly-owned subsidiary of Amarin Corporation plc, the Company applied the 12.5% Irish trading tax rate. The income tax effect of each type of temporary difference comprising the net deferred tax asset at December 31, 2014 and 2013 is as follows (in thousands):
|  | 2014 |  |  | 2013 |
Deferred tax assets: |  |  |  |  |  |  |  |
Net operating losses |  | $ | 80,096 |  |  | $ | 85,724 |
Stock based compensation |  |  | 15,600 |  |  |  | 11,660 |
Depreciation |  |  | (90 | ) |  |  | (126 | )
Tax credits |  |  | 2,141 |  |  |  | 1,256 |
Other reserves and accrued liabilities |  |  | 1,708 |  |  |  | 2,900 |
Gross deferred tax asset |  |  | 99,455 |  |  |  | 101,414 |
Less: valuation allowance |  |  | (85,965 | ) |  |  | (88,999 | )
|  | $ | 13,490 |  |  | $ | 12,415 |
The Company assesses whether it is more-likely-than-not that the Company will realize its deferred tax assets. The Company determined that it was more-likely-than-not that the Irish, UK, and Israeli net operating losses and the related deferred tax assets would not be realized in future periods and a full valuation allowance has been provided for all periods. The following table reflects the activity in the valuation allowance for the years ended December 31, 2014 and 2013 (in thousands):
|  | 2014 |  |  | 2013 |
Beginning valuation allowance |  | $ | 88,999 |  |  | $ | 55,894 |
Increase as reflected in income tax expense |  |  | 5,081 |  |  |  | 32,999 |
Cumulative translation adjustment |  |  | (8,115 | ) |  |  | 106 |
Ending valuation allowance |  | $ | 85,965 |  |  | $ | 88,999 |
The Company has combined Irish, UK, and Israeli net operating loss carryforwards of $513.3 million, which do not expire. The total net operating loss carryforwards decreased by approximately $14.9 million from the prior year primarily as a result of the impact of foreign exchange rate changes and adjustments to reconcile the financial statement accounts to the amounts reported on the filed 2013 foreign tax returns, which were in excess of current year taxable losses generated in these countries. In addition, the Company has available U.S. Federal tax credit carryforwards of $6.2 million and state tax credit carryforwards of $1.4 million. These amounts exclude the impact of any unrecognized tax benefits. These carryforwards, which will expire starting between 2020 and 2034 may be used to offset future taxable income, if any. The Company recognized a tax benefit related to the extension of the research and development credits retroactively enacted during the fourth quarter of 2014 and recorded a benefit of approximately $1.4 million for the credit generated during the year.

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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/presentationRef -Publisher FASB -Name Accounting Standards Codification -Topic 740 -SubTopic 10 -Section 50 -Paragraph 15 -URI http://asc.fasb.org/extlink&oid=6907707&loc=d3e32718-109319 Reference 2: http://www.xbrl.org/2003/role/presentationRef -Publisher FASB -Name Accounting Standards Codification -Topic 235 -SubTopic 10 -Section S99 -Paragraph 1 -Subparagraph (SX 210.4-08.(h)) -URI http://asc.fasb.org/extlink&oid=26873400&loc=d3e23780-122690 Reference 3: http://www.xbrl.org/2003/role/presentationRef -Publisher SEC -Name Regulation S-X (SX) -Number 210 -Section 08 -Paragraph h -Article 4 Reference 4: http://www.xbrl.org/2003/role/presentationRef -Publisher FASB -Name Accounting Standards Codification -Topic 740 -SubTopic 10 -Section 50 -Paragraph 9 -URI http://asc.fasb.org/extlink&oid=6907707&loc=d3e32639-109319 Reference 5: http://www.xbrl.org/2003/role/presentationRef -Publisher FASB -Name Accounting Standards Codification -Topic 740 -SubTopic 10 -Section 50 -Paragraph 2 -URI http://asc.fasb.org/extlink&oid=6907707&loc=d3e32537-109319 Reference 6: http://www.xbrl.org/2003/role/presentationRef -Publisher FASB -Name Accounting Standards Codification -Topic 740 -SubTopic 10 -Section 50 -Paragraph 3 -URI http://asc.fasb.org/extlink&oid=6907707&loc=d3e32559-109319 + Details
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