11. INCOME TAXES

The provision (benefit) for income taxes from continuing operations for the years ended December 31, 2017, 2016 and 2015 (in millions):

	2017			2016		2015
Current
Federal	$	(0.5	)	$	—	$	—
State		0.6			0.6		0.6
Foreign		0.8			—		—
	$	0.9		$	0.6	$	0.6
Deferred
Federal		70.1			12.0		12.8
State		12.5			0.5		3.0
Foreign		(0.7	)		—		—
		81.9			12.5		15.8
Total provision for taxes	$	82.8		$	13.1	$	16.4

The income tax provision (benefit) differs from the amount of income tax determined by applying the Company’s federal corporate income tax rate of 35% to pre-tax income for the years ended December 31, 2017, 2016 and 2015 due to the following (in millions):

	2017			2016		2015
Computed “expected” tax provision (benefit)	$	90.7		$	11.7	$	14.7
Change in income tax resulting from:
State taxes, net of federal benefit		8.5			1.4		2.5
Change in federal tax rate		(17.3	)		—		—
Other		0.9			—		(0.8	)
	$	82.8		$	13.1	$	16.4

The components of the deferred tax assets and liabilities at December 31, 2017 and 2016 consist of the following (in millions):

		2017			2016
Deferred tax assets:
Accrued expenses	$	1.8		$	3.4
Accounts receivable		0.6			1.0
Net operating loss carryforward		77.6			116.7
Stock-based compensation		0.9			1.8
Intangible assets		—			8.0
Credits		0.7			1.0
Property and equipment		—			0.4
Deferred state taxes		2.3			—
Other		1.4			2.5
Net deferred tax assets	$	85.3		$	134.8
Deferred tax liabilities:
Intangible assets	$	(57.3	)	$	(89.6	)
Property and equipment		(0.2	)		—
Deferred state taxes		—			(0.5	)
Tax gain deferral - FCC auction for broadcast spectrum		(68.6	)		—
		(126.1	)		(90.1	)
	$	(40.8	)	$	44.7

As of December 31, 2017, the Company has federal and state net operating loss carryforwards of approximately $316 million and $222 million, respectively, available to offset future taxable income. The federal net operating loss carryforwards will expire during the years 2020 through 2033, to the extent they are not utilized. The state net operating loss carryforwards will expire during the years 2018 through 2033, to the extent they are not utilized. Of the $222 million of state net operating loss carryforwards, $0.7 million will expire in 2018.

Utilization of the Company’s U.S. federal and certain state net operating loss and tax credit carryovers may be subject to substantial annual limitation due to the ownership change limitations provided by the Internal Revenue Code and similar state provisions. Such an annual limitation could result in the expiration of the net operating loss carryforwards before utilization. As of December 31, 2017, the Company believes that utilization of its federal net operating losses and foreign tax credits are not limited under any ownership change limitations provided under the Internal Revenue Code.

The Company periodically evaluates the realizability of the deferred tax assets and, if it is determined that it is more likely than not that the deferred tax assets are realizable, adjusts the valuation allowance accordingly. Valuation allowances are established and maintained for deferred tax assets on a “more likely than not” threshold. The process of evaluating the need to maintain a valuation allowance for deferred tax assets is highly subjective and requires significant judgment. The Company has considered the following possible sources of taxable income when assessing the realization of the deferred tax assets: (1) future reversals of existing taxable temporary differences; (2) taxable income in prior carryback years; (3) future taxable income exclusive of reversing temporary differences and carryforwards; and (4) tax planning strategies. Based on the Company’s analysis and a review of all positive and negative evidence such as historical operations, future projections of taxable income and tax planning strategies that are prudent and feasible, the Company determined that it was more likely than not that the deferred tax assets will be realized.

The Tax Act reduces the corporate tax rate from 35% to 21%, effective January 1, 2018. As a result, the Company has recorded a provisional decrease in value of its net deferred tax liabilities of $17.3 million, with a corresponding net adjustment to deferred income tax benefit of $17.3 million for the year ended December 31, 2017. The Company is able to make a reasonable estimate of the impact of the reduction in the corporate tax rate and no significant provisional items were identified that could result in a material impact to the estimate upon finalization in 2018.

The Company addresses uncertainty in tax positions according to the provisions of ASC 740, “Income Taxes”, which clarifies the accounting for income taxes by establishing the minimum recognition threshold and a measurement attribute for tax positions taken or expected to be taken in a tax return in order to be recognized in the financial statements.

The following table summarizes the activity related to the Company’s unrecognized tax benefits (in millions):

	Amount
Balance at December 31, 2015	$	6.3
Change in balances related to tax positions		0.0
Balance at December 31, 2016	$	6.3
Change in balances related to tax positions		0.0
Balance at December 31, 2017	$	6.3

As of December 31, 2017, the Company had $6.3 million of gross unrecognized tax benefits for uncertain tax positions, of which $0.8 million would affect the effective tax rate if recognized.

The Company does not anticipate that the amount of unrecognized tax benefits as of December 31, 2017 will significantly increase or decrease within the next 12 months.

The Company recognizes interest and penalties related to income tax matters as a component of income tax expense. As of December 31, 2017, the Company had no significant accrued interest and penalties related to uncertain tax positions due to the net operating losses.

The Company is subject to taxation in the United States, various states, and various foreign jurisdictions. The tax years 2014 to 2016 and 2013 to 2016 remain open to examination by federal and state taxing jurisdictions, respectively. For foreign jurisdictions, the tax years 2006 to 2016 may remain open to examination by certain foreign jurisdictions. Net operating losses from years from which the statute of limitations have expired (2013 and prior for federal and 2012 and prior for state) could be adjusted in the event that the taxing jurisdictions challenge the amounts of net operating loss carryforwards from such years.