Juno 2014 Annual Report Download - page 120

Table of Contents
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
$48.2 million for net unrealizable deferred tax assets, excluding indefinite-lived assets, was recorded at December 31, 2014.
Subsequent to the FTD Spin-Off Transaction in the quarter ended December 31, 2013, the Company performed an extensive evaluation for a valuation
allowance against its net deferred tax assets, excluding indefinite-lived assets. In its evaluation of positive and negative evidence, the Company determined
that the negative evidence was more persuasive, which led the Company to record a full valuation allowance against its domestic net deferred tax assets,
excluding indefinite-lived assets and net operating loss carryback. The Company had a valuation allowance totaling $48.2 million and $47.0 million at
December 31, 2014 and 2013, respectively, to reduce domestic net deferred tax assets to an amount that is more likely than not to be realized in future
periods. The valuation allowance relates to domestic net deferred tax assets, including federal and state net operating loss carryforwards, member redemption
liability and foreign tax credit carryforwards.
At December 31, 2014 and 2013, the Company had gross unrecognized tax benefits totaling $8.6 million and $9.0 million, respectively, of which
$8.6 million and $9.0 million, respectively, would have an impact on the Company's effective income tax rate, if recognized. The effective income tax rate
impact is inclusive of changes in valuation allowance resulting from recognition of previously unrecognized tax benefits. 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 examination by the IRS and state, local and foreign jurisdictions, except for items involving tax attributes that have been
carried forward to tax years whose statute of limitations remains open.
F-38
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     
Beginning balance $ 9,037 $ 4,218 $ 4,724
Additions for current year tax positions 119 324 263
Reductions for current year tax positions (625) (268) (81)
Additions for prior year tax positions 895 5,565 625
Reductions for prior year tax positions (737) (440) —
Reductions related to settlements with taxing authorities (64) (286) (470)
Reductions due to lapse in statutes of limitations — (76) (843)
Ending balance $ 8,625 $ 9,037 $ 4,218