Alpha Metallurgical Resources Inc
For the period ended Dec 31, 2023. Filed Feb 26, 2024.
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FY2023 · Filed Feb 26, 2024
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(17) Income Taxes
Significant components of income tax expense (benefit) were as follows:
| Year Ended December 31, | |||
|---|---|---|---|
| 2023 | 2022 | 2021 | |
| Current tax expense: | |||
| Federal | $80,254 | $114,106 | $2,422 |
| State | 3,527 | 6,620 | 1,149 |
| Total current | $83,781 | $120,726 | $3,571 |
| Deferred tax expense (benefit): | |||
| Federal | $35,824 | $(1,726) | $(3) |
| State | 3,898 | (12,795) | (160) |
| Total deferred | $39,722 | $(14,521) | $(163) |
| Total income tax expense (benefit): | |||
| Federal | $116,078 | $112,380 | $2,419 |
| State | 7,425 | (6,175) | 989 |
| Total | $123,503 | $106,205 | $3,408 |
A reconciliation of statutory federal income tax expense on income to the actual income tax expense is as follows:
| Year Ended December 31, | |||
|---|---|---|---|
| 2023 | 2022 | 2021 | |
| Federal statutory income tax expense | $177,547 | $326,497 | $61,362 |
| Increase (decrease) in taxes due to: | |||
| Percentage depletion allowance | (36,685) | (50,277) | (11,864) |
| Foreign-derived intangible income deduction | (24,291) | (69,917) | (1,453) |
| Change in valuation allowances | (5,658) | (119,082) | (78,043) |
| State taxes, net of federal tax impact | 5,932 | 14,625 | 12,440 |
| State apportioned tax rate change, net of federal tax impact | 2,863 | 273 | 8,751 |
| Capital loss carryforward expiration | — | 140 | 10,552 |
| Non-deductible compensation | 9,934 | 5,573 | 1,429 |
| Stock-based compensation | (6,968) | (3,588) | 405 |
| Other, net | 829 | 1,961 | (171) |
| Income tax expense | $123,503 | $106,205 | $3,408 |
Deferred income taxes result from temporary differences between the reporting of amounts for financial statement purposes and income tax purposes. The net deferred tax assets and liabilities included in the Consolidated Balance Sheets include the following amounts:
| Year Ended December 31, | ||
|---|---|---|
| 2023 | 2022 | |
| Deferred tax assets: | ||
| Asset retirement obligations | $44,600 | $39,200 |
| Reserves and accruals not currently deductible | 8,141 | 10,572 |
| Workers’ compensation and black lung obligations | 39,432 | 38,099 |
| Pension obligations | 18,409 | 23,826 |
| Equity method investments | 1,271 | 1,555 |
| Net operating loss carryforwards | 35,835 | 43,716 |
| Capital loss carryforwards | 45,491 | 48,940 |
| Acquisition-related obligations | — | 6,194 |
| Other | 9,496 | 7,171 |
| Gross deferred tax assets | 202,675 | 219,273 |
| Less valuation allowance | (48,143) | (53,801) |
| Deferred tax assets | $154,532 | $165,472 |
| Deferred tax liabilities: | ||
| Property, plant and mineral reserves | $(172,336) | $(148,189) |
| Acquired intangibles, net | (9,478) | (11,995) |
| Prepaid expenses | (3,658) | (4,215) |
| Restricted cash | — | (556) |
| Other | (174) | (13) |
| Total deferred tax liabilities | (185,646) | (164,968) |
| Net deferred tax (liabilities) assets | $(31,114) | $504 |
Changes in the valuation allowance were as follows:
| Year Ended December 31, | |||
|---|---|---|---|
| 2023 | 2022 | 2021 | |
| Valuation allowance beginning of period | $53,801 | $172,883 | $263,387 |
| Decrease in valuation allowance recorded to income tax expense | (5,658) | (119,082) | (78,043) |
| Decrease in valuation allowance not affecting income tax expense | — | — | (12,461) |
| Valuation allowance end of period | $48,143 | $53,801 | $172,883 |
At December 31, 2023, the Company has recorded a deferred tax asset of $26,494 for federal net operating loss carryforwards, which represents the tax-effected amount of net operating loss carryforwards mathematically available for utilization prior to statutory expiration. Underlying this deferred tax asset are approximately $12,000 of gross federal net operating loss carryforwards that are subject to an annual Internal Revenue Code Section 382 limitation of approximately $1,000 and approximately $114,000 of gross federal net operating loss carryforwards that are subject to an annual Internal Revenue Code Section 382 limitation of approximately $17,500. These federal net operating loss carryforwards were generated before 2018 and will expire between years 2035 and 2037. The Company has a gross federal capital loss carryforward of approximately $208,000. The capital loss carryforward will expire in 2025. A valuation allowance is recorded against the federal and state capital loss carryforwards and certain state net operating loss carryforwards.
The Company hasno liability for uncertain tax positions for the years ended December 31, 2023, 2022, and 2021.
The Company’s policy is to classify interest and penalties related to uncertain tax positions as part of income tax expense. As of December 31, 2023 and 2022, the Company hadno accrued interest and penalties.
As of December 31, 2023, tax years 2020 – 2023 remain open to federal and state examination. During the third quarter of 2021, the IRS concluded its audit of the Company’s 2016 federal income tax return and associated net operating loss (“NOL”) carryback claim. The audit conclusion did not result in any material impact to the financial statements or related disclosures. Following the conclusion of the audit, the Company received the $64,160 carryback claim tax refund and $5,425 of accrued interest.
On August 16, 2022, the Inflation Reduction Act of 2022 (“IRA”) was signed into law. Among other provisions, the IRA enacted a 15% corporate alternative minimum tax and a 1% excise tax on repurchases of corporate stock for tax years beginning after December 31, 2022. The Company determined that it is not subject to the corporate alternative minimum tax for the year ended December 31, 2023. Refer to Note 7 for information on the excise tax on repurchases of the Company’s corporate stock.
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