Juno 2013 Annual Report Download - page 135

Table of Contents
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Subsequent to the FTD Spin-Off Transaction in the quarter ended December 31, 2013, the Company performed an extensive evaluation in
connection with the need for a valuation allowance against its net deferred tax assets, excluding indefinite-lived assets. In its evaluation of positive and
negative evidence, the Company has determined that the negative evidence was more persuasive, which has led the Company to record a full valuation
allowance against its domestic net deferred tax assets, excluding indefinite-lived assets. The Company had a valuation allowance of $43.8 million and
$6.3 million at December 31, 2013 and 2012, respectively, to reduce deferred tax assets to an amount that is more likely than not to be realized in future
periods. The valuation allowance relates to domestic deferred tax assets, including federal and state net operating loss carryforwards, member
redemption liability and foreign tax credit carryforwards.
At December 31, 2013 and 2012, the Company had gross unrecognized tax benefits totaling $9.3 million and $4.5 million, respectively, of which
$3.9 million and $3.7 million, respectively, would have an impact on the Company's effective income tax rate, if recognized. A reconciliation of the
beginning and ending amounts of gross unrecognized tax benefits (before federal impact of state items), excluding interest and penalties, was as follows
(in thousands):
The Company files income tax returns in the U.S., various state and local jurisdictions, Germany, and certain other foreign jurisdictions. The
Company is currently under audit by the Internal Revenue Service ("IRS"), certain state and local, and foreign tax authorities. The audits are in varying
stages of completion. The Company evaluates its tax positions and establishes liabilities for uncertain tax positions that may be challenged by tax
authorities. Uncertain tax positions are reviewed on an ongoing basis and are adjusted in light of changing facts and circumstances, including progress
of tax audits, case law developments and closing of statutes of limitations. Such adjustments are reflected in the provision for income taxes, as
appropriate. Tax years prior to 2009 are generally not subject to
F-41
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    
Current deferred tax assets, net $ 291 $ 6,397
Non-current deferred tax assets, net 1,742 31,059
Current deferred tax liabilities, net (671) —
Non-current deferred tax liabilities, net (1,606) (403)
Net deferred tax assets (liabilities) $ (244) $ 37,053
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     
Beginning balance $ 4,469 $ 4,352 $ 8,262
Additions for current year tax positions 271 263 965
Reductions for current year tax positions (172) — —
Additions for prior year tax positions 5,565 625 527
Reductions for prior year tax positions (440) — —
Reductions related to settlements with taxing authorities (286) (470) (5,299)
Reductions due to lapse in statutes of limitations (76) (301) (103)
Ending balance $ 9,331 $ 4,469 $ 4,352