12. Income Taxes

The Company’s components of loss before income taxes are as follows:


	Year Ended December 31,				Three Months Ended December 31,		Year Ended September 30,
	2016		2015		2014		2014
Loss before income taxes
Domestic	$	(41,162,000)	$	(36,230,000)	$	(6,249,000)	$	(11,671,000)
Foreign		(5,079,000)		(3,804,000)		(654,000)		(6,229,000)
Total	$	(46,241,000)	$	(40,034,000)	$	(6,903,000)	$	(17,900,000)

The Company recorded income tax benefit of $6,449,000 and $13,755,000 in the years ended December 31, 2016 and 2015, respectively. The Company recorded income tax benefit of $1,912,000 and $5,280,000 in the three months ended December 31, 2014 and year ended September 30, 2014 respectively.

Income tax benefit was comprised of the following:


	Year Ended December 31,				Three Months Ended December 31,		Year Ended September 30,
	2016		2015		2014		2014
Current federal benefit	$	215,000	$	280,000	$	—	$	74,000
Current state benefit (expense)		181,000		(571,000)		(39,000)		(633,000)
Current foreign expense		—		—		—		(228,000)
Deferred federal benefit		5,795,000		12,499,000		1,783,000		5,489,000
Deferred state (expense) benefit		(847,000)		860,000		168,000		578,000
Deferred foreign benefit		1,105,000		687,000		—		—
Total	$	6,449,000	$	13,755,000	$	1,912,000	$	5,280,000

The income tax provision differs from the amount computed by applying the statutory federal income tax rate to losses before income taxes as follows:


	Year Ended December 31,				Three Months Ended December 31,		Year Ended September 30,
	2016		2015		2014		2014
Tax benefit computed at statutory rate of 35%	$	16,184,000	$	14,012,000	$	2,416,000	$	6,265,000
Change in valuation allowance		(10,200,000)		(502,000)		(170,000)		(1,506,000)
State income tax (expense) benefit, net of federal tax		(433,000)		423,000		83,000		(32,000)
Foreign losses		985,000		954,000		170,000		1,506,000
Transaction costs		—		(445,000)		(522,000)		(332,000)
Other		(87,000)		(687,000)		(65,000)		(621,000)
Income tax benefit	$	6,449,000	$	13,755,000	$	1,912,000	$	5,280,000

The principal components of the Company’s net deferred tax assets (liabilities) are as follows:


	December 31,
	2016		2015
Deferred tax assets:
Federal tax net operating loss ("NOL") carry forward	$	32,746,000	$	23,002,000
Foreign tax NOL carry forward		4,486,000		3,694,000
Deferred revenue		462,000		1,193,000
Restricted stock		318,000		214,000
Workers’ compensation		74,000		144,000
State tax NOL carry forward		1,223,000		850,000
Self-insurance		219,000		260,000
Canadian start-up costs		275,000		296,000
Alternative Minimum Tax credit carry forward		315,000		315,000
Foreign tax credit		1,874,000		1,874,000
Other comprehensive income		786,000		1,055,000
Uncertain tax positions		512,000		562,000
Other		(264,000)		(91,000)
Total gross deferred tax assets		43,026,000		33,368,000
Less valuation allowances		(13,602,000)		(3,707,000)
Total net deferred tax assets		29,424,000		29,661,000
Deferred tax liabilities:
Property and equipment		(29,035,000)		(34,980,000)
Total net deferred tax assets (liabilities)	$	389,000	$	(5,319,000)
Noncurrent portion of foreign deferred tax assets	$	535,000	$	—
Noncurrent portion of domestic deferred tax liabilities		(146,000)		(5,319,000)
Total net deferred tax assets (liabilities)	$	389,000	$	(5,319,000)

At December 31, 2016, the Company had a gross NOL for U.S. federal income tax purposes of approximately $93,802,000. This NOL will begin to expire in 2027. The Company will carry forward the net federal NOL of approximately $32,746,000. The Company also had state NOL’s that will affect state taxes of approximately $1,881,000 at December 31, 2016. State NOL’s began to expire in 2015. The Company also has a Canadian NOL of $17,253,000 that will begin to expire in 2032.

In evaluating the possible sources of taxable income during 2016, the Company determined it is more likely than not that the remaining deferred tax assets will not be realizable. As a result, the Company recorded full valuation allowances against its federal, state, and foreign deferred tax assets with the exception of its trademark intangible and the foreign deferred tax assets associated with NOL’s that can be carried back against prior losses.

A summary of the Company’s gross uncertain tax positions at December 31, 2016 and 2015 as well as activity for the years then ended are as follows:


	December 31,
	2016		2015
Balance at beginning of year	$	1,684,000	$	—
Established at Merger date		—		715,000
(Decrease) increase in prior year tax positions		(14,000)		455,000
Increase in current year tax positions		157,000		514,000
Liability statute expiration		(338,000)		—
Balance at end of year	$	1,489,000	$	1,684,000

There were no uncertain tax positions for the three months ended December 31, 2014 and the year ended September 30, 2014. The tax years generally subject to future examination by tax authorities are for the years ended December 31, 2013 and after. The Company’s policy is to recognize interest and penalties related to uncertain tax positions in income tax expense.

Due to the potential resolution of amended federal, state and foreign tax returns and the expiration of various statutes of limitations, it is reasonably possible that the full uncertain tax positions balance at December 31, 2016 may reverse within the next 12 months.