Income Taxes (Tables)
|
12 Months Ended |
Dec. 31, 2023 |
Income Tax Disclosure [Abstract] |
|
Schedule of (Benefit) Provision for Income Taxes from Continuing Operations |
The Company’s (benefit) provision for income taxes from continuing operations consists of the following:
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Year Ended December 31, |
|
(In thousands) |
|
2023 |
|
|
2022 (1) |
|
|
2021 (1) |
|
Current income tax (benefit) provision: |
|
|
|
|
|
|
|
|
|
U.S. federal |
|
$ |
(981 |
) |
|
$ |
11,169 |
|
|
$ |
2,251 |
|
U.S. state |
|
|
722 |
|
|
|
4,401 |
|
|
|
797 |
|
Rest of world |
|
|
— |
|
|
|
— |
|
|
|
3 |
|
Deferred income tax (benefit) provision: |
|
|
|
|
|
|
|
|
|
U.S. federal |
|
|
10,192 |
|
|
|
(10,536 |
) |
|
|
9,372 |
|
U.S. state |
|
|
(507 |
) |
|
|
(3,010 |
) |
|
|
(1,097 |
) |
Ireland |
|
|
(107,064 |
) |
|
|
— |
|
|
|
— |
|
Total tax (benefit) provision |
|
$ |
(97,638 |
) |
|
$ |
2,024 |
|
|
$ |
11,326 |
|
(1)Prior period amounts have been retrospectively adjusted to reflect the effects of the Separation.
|
Schedule of Income (Loss) Before (Benefit) Provision for Income Taxes by Geographical Area |
The distribution of the Company’s income (loss) before the (benefit) provision for income taxes by geographical area consists of the following:
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Year Ended December 31, |
|
(In thousands) |
|
2023 |
|
|
2022 (1) |
|
|
2021 (1) |
|
Ireland |
|
$ |
411,767 |
|
|
$ |
(32,198 |
) |
|
$ |
85,415 |
|
U.S. |
|
|
9,752 |
|
|
|
1,070 |
|
|
|
2,312 |
|
Income (loss) from continuing operations before (benefit) provision for income taxes |
|
$ |
421,519 |
|
|
$ |
(31,128 |
) |
|
$ |
87,727 |
|
(1)Prior period amounts have been retrospectively adjusted to reflect the effects of the Separation.
|
Schedule of Components of Net Deferred Tax Assets |
The components of the Company’s net deferred tax assets consist of the following:
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December 31, |
|
|
December 31, |
|
(In thousands) |
|
2023 |
|
|
2022 (1) |
|
Deferred tax assets: |
|
|
|
|
|
|
Net operating loss carryforwards |
|
$ |
195,658 |
|
|
$ |
238,128 |
|
Research and development expenses |
|
|
49,206 |
|
|
|
66,464 |
|
Accrued expenses and reserves |
|
|
56,083 |
|
|
|
51,362 |
|
Share-based compensation |
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|
37,727 |
|
|
|
39,333 |
|
Tax credits |
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|
27,116 |
|
|
|
22,932 |
|
Other |
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|
5,582 |
|
|
|
6,543 |
|
Less: valuation allowance |
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|
(129,296 |
) |
|
|
(268,067 |
) |
Total deferred tax assets |
|
|
242,076 |
|
|
|
156,695 |
|
Deferred tax liabilities: |
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|
|
|
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Property, plant and equipment |
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|
(44,019 |
) |
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|
(41,169 |
) |
Other |
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|
(2,716 |
) |
|
|
(1,502 |
) |
Total deferred tax liabilities |
|
|
(46,735 |
) |
|
|
(42,671 |
) |
Net deferred tax assets |
|
$ |
195,341 |
|
|
$ |
114,024 |
|
(1)Prior period amounts have been retrospectively adjusted to reflect the effects of the Separation.
|
Schedule of Activity in Valuation Allowance Associated with Deferred taxes |
The activity in the valuation allowance associated with deferred taxes consists of the following:
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(In thousands) |
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Balance at Beginning of Period (1) |
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(Additions) / Reductions (2) |
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Balance at End of Period (1) |
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Deferred tax asset valuation allowance for the year ended December 31, 2021 |
|
$ |
(253,649 |
) |
|
$ |
4,537 |
|
|
$ |
(249,112 |
) |
Deferred tax asset valuation allowance for the year ended December 31, 2022 |
|
$ |
(249,112 |
) |
|
$ |
(22,405 |
) |
|
$ |
(271,517 |
) |
Deferred tax asset valuation allowance for the year ended December 31, 2023 |
|
$ |
(271,517 |
) |
|
$ |
142,221 |
|
|
$ |
(129,296 |
) |
(1)Inclusive of continuing and discontinued operations for all periods other than the balance at December 31, 2023. (2)(Additions) reductions represent continuing and discontinued operations. The reduction during the year ended December 31, 2023 primarily relates to the partial release of the valuation allowance maintained against certain Irish net deferred tax assets. The (additions) reductions in 2022 and 2021 relate primarily to Irish net operating losses (“NOLs”).
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Schedule of Reconciliation of Statutory Tax Rate to Effective Tax Rate |
A reconciliation of the Company’s statutory tax rate to its effective tax rate is as follows:
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Year Ended December 31, |
|
|
(In thousands, except percentage amounts) |
|
2023 |
|
|
|
2022 (1) |
|
|
|
2021 (1) |
|
|
Statutory tax rate |
|
|
12.5 |
|
% |
|
|
12.5 |
|
% |
|
|
12.5 |
|
% |
|
|
|
|
|
|
|
|
|
|
|
|
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Income (loss) from continuing operations before income taxes at statutory rate |
|
$ |
52,690 |
|
|
|
$ |
(3,891 |
) |
|
|
$ |
10,966 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Share-based compensation |
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|
4,177 |
|
|
|
|
4,347 |
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|
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|
7,716 |
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Foreign rate differential(2) |
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|
4,701 |
|
|
|
|
521 |
|
|
|
|
5,159 |
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|
Change in valuation allowance |
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|
(142,424 |
) |
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|
|
1,102 |
|
|
|
|
(23,024 |
) |
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Intercompany amounts(3) |
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|
(16,551 |
) |
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|
|
(1,694 |
) |
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|
|
10,707 |
|
|
Irish rate differential(4) |
|
|
235 |
|
|
|
|
4,926 |
|
|
|
|
1,817 |
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Uncertain tax positions |
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|
(234 |
) |
|
|
|
602 |
|
|
|
|
704 |
|
|
Non-deductible lobbying expenses |
|
|
705 |
|
|
|
|
775 |
|
|
|
|
637 |
|
|
U.S. state income taxes, net of U.S. federal benefit |
|
|
347 |
|
|
|
|
1,272 |
|
|
|
|
(260 |
) |
|
In-process R&D(5) |
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|
— |
|
|
|
|
— |
|
|
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|
2,724 |
|
|
Foreign derived intangible income |
|
|
— |
|
|
|
|
(4,530 |
) |
|
|
|
(3,125 |
) |
|
R&D credit |
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|
(2,823 |
) |
|
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(2,531 |
) |
|
|
|
(2,871 |
) |
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Other permanent items(6) |
|
|
1,539 |
|
|
|
|
1,125 |
|
|
|
|
176 |
|
|
Income tax (benefit) provision |
|
$ |
(97,638 |
) |
|
|
$ |
2,024 |
|
|
|
$ |
11,326 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Effective tax rate |
|
|
(23.2 |
) |
% |
|
|
(6.5 |
) |
% |
|
|
12.9 |
|
% |
(1)Prior period amounts have been retrospectively adjusted to reflect the effects of the Separation. (2)Represents income or losses of U.S. subsidiaries, subject to tax at a rate other than the Irish statutory rate. (3)Intercompany amounts include cross-territory eliminations, the pre-tax effect of which has been eliminated in arriving at the Company's consolidated income (loss) before taxes from continuing operations. In 2023, this included a tax benefit of $15.7 million related to the intercompany transfer of inventory that was owned by the Company at December 31, 2023. (4)Represents income or losses of Irish companies subject to tax at a rate other than the Irish statutory rate. (5)Represents the tax effect of the research and development expense recorded in connection with the acquisition of Rodin. (6)Other permanent items include, but are not limited to, non-deductible meals and entertainment expenses and non-deductible compensation of senior officers of the Company.
|
Schedule of Reconciliation of Beginning and Ending Amount of Unrecognized Tax Benefits |
A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows:
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Unrecognized |
|
(In thousands) |
|
Tax Benefits |
|
Balance, December 31, 2020 |
|
$ |
7,668 |
|
Reductions based on tax positions related to prior periods |
|
|
(27 |
) |
Additions based on tax positions related to the current period |
|
|
731 |
|
Balance, December 31, 2021 |
|
$ |
8,372 |
|
Reductions based on the lapse of applicable statutes of limitations |
|
|
(438 |
) |
Additions based on tax positions related to prior periods |
|
|
449 |
|
Additions based on tax positions related to the current period |
|
|
590 |
|
Balance, December 31, 2022 |
|
$ |
8,973 |
|
Reductions based on the lapse of applicable statutes of limitations |
|
|
(1,073 |
) |
Additions based on tax positions related to the prior period |
|
|
281 |
|
Additions based on tax positions related to the current period |
|
|
558 |
|
Balance, December 31, 2023 |
|
$ |
8,739 |
|
|