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Note 3 - Income Taxes
3 Months Ended
Jun. 30, 2016
Notes to Financial Statements  
Income Tax Disclosure [Text Block]
3.
Income Taxes
 
Income taxes have been provided using the asset and liability method. Deferred tax assets and liabilities are recognized for the future tax consequences attributable to differences between the financial statement carrying amounts of existing assets and liabilities and their respective tax bases. Deferred tax assets and liabilities are measured using enacted tax laws and rates expected to apply to taxable income in the years in which those temporary differences are expected to be recovered or settled. The effect of a change in tax rates on deferred tax assets and liabilities is recognized in income in the period that includes the enactment date.
 
During the
three
-month period ended
June 30, 2016,
the Company recorded
$372,000
in income tax benefit, which resulted in an effective tax rate of
4.4%.
The Company records income taxes using an estimated annual effective tax rate for interim reporting. Under the annual effective tax rate method, jurisdictions with a projected loss where
no
tax benefit can be recognized are excluded from the calculation of the estimated annual effective tax rate. The individually largest factor contributing to the difference between the federal statutory rate and the Company
’s effective tax rate for the
June 2016
quarter was the recognition of a valuation allowance against Delphax’s pretax loss in the period. The income tax provision for the
three
-month period ended
June 30, 2016
differs from the federal statutory rate due also in part to the effect of state income taxes and the federal domestic production activities deduction. Additionally, the rate for the period ended
June 30, 2016
includes the estimated benefit for the exclusion of income for the Company’s captive insurance company subsidiary afforded under Section
831
(b). During the
three
-month period ended
June 30, 2015,
the Company recorded
$333,000
in income tax benefit. The start-up of SAIC was a significant factor in the prior period estimated annual tax rate of
34.3%.
The estimated annual effective tax rate differed from the U. S. federal statutory rate of
34%
primarily due to the effect of state income taxes offset by permanent tax differences.
 
As described in Note
2,
effective on
November 24, 2015,
Air T, Inc. purchased interests in Delphax. With an equity investment level by the Company of approximately
38%,
Delphax is required to continue filing a separate United States corporate tax return. Furthermore, Delphax has
three
foreign subsidiaries located in Canada, France, and the United Kingdom which file tax returns in those jurisdictions. With few exceptions, Delphax is
no
longer subject to examinations by income tax authorities for tax years before
2011.
 
Delphax maintains a
September 30
fiscal year. As of
September 30, 2015,
Delphax and its subsidiaries had estimated foreign and domestic tax loss carryforwards of
$6.0
million and
$7.9
million, respectively. As of that date, they had estimated foreign research and development credit carryforwards of
$4.5
million, which are available to offset future income tax. The credits and net operating losses expire in varying amounts beginning in the year
2023.
Domestic alternative minimum tax credits of approximately
$325,000
are available to offset future income tax with
no
expiration date. Should there be an ownership change for purposes of Section
382
or any equivalent foreign tax rules, the utilization of the previously mentioned carryforwards
may
be significantly limited. Additionally, based on the anticipated liquidation of Delphax Canada,
$3.2
million of the previously disclosed foreign tax loss carryforwards,
$4.5
million of foreign research and development credit carryforwards, as well as other temporary differences such as fixed asset basis differences will likely go unutilized. See additional information regarding Delphax Canada in Note
9.
 
The provisions of ASC
740
require an assessment of both positive and negative evidence when determining whether it is more-likely-than-
not
that deferred tax assets will be recovered. In accounting for the Delphax acquisition on
November 24, 2015,
the Company established a full valuation allowance against Delphax
’s net deferred tax assets of approximately
$11,661,000.
The corresponding valuation allowance at
June 30, 2016
was approximately
$12,772,000.
The cumulative losses incurred by Delphax in recent years was the primary basis for the Company’s determination that a full valuation allowance should be established.
 
The Company has
not
recognized any deferred income tax assets or liabilities associated with differences between the financial reporting and tax reporting bases of investments in foreign subsidiaries or for outside basis differences associated with the Company
’s investments in Delphax. The Company concluded that the conditions for such recognition were
not
met as of
June 30, 2016.
The differences in question would lead to taxable or deductible amounts upon certain events, including a repatriation of foreign assets or a sale or liquidation of the respective entity. Determination of the amount of any unrecognized deferred income tax assets or liabilities on these differences is
not
practicable at this time due to the complexities of the hypothetical calculation.