ALLIANCE RESOURCE PARTNERS LP

Components of income tax expense are as follows:

Alliance Minerals’ Tax Election resulted in the recognition of an initial deferred tax liability of $37.3 million with a corresponding increase to income tax expense and reduction of net income for the year ended December 31, 2022. Recognition of the initial deferred tax liability and expense is primarily the result of the $177.0 million non-cash acquisition gain recognized in 2019 related to the acquisition of the remaining interests in AllDale I & II (the “Acquisition Gain”). The Acquisition Gain was recognized to step up to fair value the financial reporting basis of the interests we already owned at the time of acquisition. The tax basis of the underlying properties of AllDale I & II did not include the Acquisition Gain.

Reconciliations of income taxes at the U.S. federal statutory tax rate to income taxes at our effective tax rate are as follows:

The effective income tax rates for our income tax expense for the years ended December 31, 2024 and 2023 are less than the federal statutory rate, primarily due to the portion of income not subject to income taxes. The effective income tax rate for our income tax expense for the year ended December 31, 2022 is less than the federal statutory rate, primarily due to the portion of income not subject to income taxes, partially offset by the effect of the Tax Election previously discussed.

Significant components of deferred tax liabilities and deferred tax assets are as follows:

Deferred tax liabilities for property, plant and equipment are primarily the result of the Alliance Minerals’ Tax Election and associated impact of the Acquisition Gain discussed above. Deferred tax liabilities for digital assets are due to the remeasurement of our digital assets to fair value, which is not taxable until the digital asset is sold.

Federal and state loss carryovers and credits are primarily due to net operating losses and research and development credits associated with the operations of other subsidiaries that are taxable for federal income tax purposes. Research and development expenses are required to be capitalized and amortized for U.S. tax purposes, resulting in a deferred tax asset. These expenses are primarily associated with the operations of other subsidiaries that are taxable for federal income tax purposes. Deferred tax assets for federal loss carryovers and credits generally do not have an expiration date. Deferred tax assets for state loss carryovers and credits generally expire between 2027 and 2044 with some carryovers having indefinite carryforward periods.

Our 2020 through 2023 tax years remain open to examination by tax authorities, and lower-tier partnership income tax returns for the tax years ended December 31, 2020 and 2021 are being audited by the Internal Revenue Service.