Income Taxes (Tables)
|
12 Months Ended |
Dec. 31, 2021 |
Income Tax Disclosure [Abstract] |
|
Schedule of Provision (Benefit) for Income Taxes |
The Company’s provision (benefit) for income taxes consists of the following:
|
|
Year Ended December 31, |
|
(In thousands) |
|
2021 |
|
|
2020 |
|
|
2019 |
|
Current income tax provision (benefit): |
|
|
|
|
|
|
|
|
|
|
|
|
U.S. federal |
|
$ |
2,700 |
|
|
$ |
2,943 |
|
|
$ |
(471 |
) |
U.S. state |
|
|
1,079 |
|
|
|
1,396 |
|
|
|
354 |
|
Rest of world |
|
|
3 |
|
|
|
— |
|
|
|
— |
|
Deferred income tax provision (benefit): |
|
|
|
|
|
|
|
|
|
|
|
|
U.S. federal |
|
|
5,908 |
|
|
|
9,876 |
|
|
|
(1,503 |
) |
U.S. state |
|
|
(827 |
) |
|
|
109 |
|
|
|
881 |
|
Ireland |
|
|
— |
|
|
|
— |
|
|
|
303 |
|
Total tax provision (benefit) |
|
$ |
8,863 |
|
|
$ |
14,324 |
|
|
$ |
(436 |
) |
|
Schedule of (Loss) Income Before Provision for Income Taxes by Geographical Area |
The distribution of the Company’s loss before the provision (benefit) for income taxes by geographical area consists of the following:
|
|
Year Ended December 31, |
|
(In thousands) |
|
2021 |
|
|
2020 |
|
|
2019 |
|
Ireland |
|
$ |
(54,070 |
) |
|
$ |
(138,070 |
) |
|
$ |
(141,869 |
) |
U.S. |
|
|
14,764 |
|
|
|
41,599 |
|
|
|
(55,102 |
) |
Rest of world |
|
|
— |
|
|
|
(66 |
) |
|
|
(85 |
) |
Loss before provision (benefit) for income taxes |
|
$ |
(39,306 |
) |
|
$ |
(96,537 |
) |
|
$ |
(197,056 |
) |
|
Schedule of Components of Net Deferred Tax Assets (Liabilities) |
The components of the Company’s net deferred tax assets (liabilities) consists of the following:
|
|
December 31, |
|
|
December 31, |
|
(In thousands) |
|
2021 |
|
|
2020 |
|
Deferred tax assets: |
|
|
|
|
|
|
|
|
NOL carryforwards |
|
$ |
222,508 |
|
|
$ |
233,755 |
|
Tax credits |
|
|
58,704 |
|
|
|
59,098 |
|
Accrued expenses and reserves |
|
|
52,308 |
|
|
|
49,730 |
|
Share-based compensation |
|
|
40,455 |
|
|
|
44,480 |
|
Other |
|
|
7,758 |
|
|
|
6,651 |
|
Less: valuation allowance |
|
|
(249,112 |
) |
|
|
(253,649 |
) |
Total deferred tax assets |
|
|
132,621 |
|
|
|
140,065 |
|
Deferred tax liabilities: |
|
|
|
|
|
|
|
|
Property, plant and equipment |
|
|
(50,187 |
) |
|
|
(52,707 |
) |
Other |
|
|
(1,150 |
) |
|
|
(1,697 |
) |
Total deferred tax liabilities |
|
|
(51,337 |
) |
|
|
(54,404 |
) |
Net deferred tax assets |
|
$ |
81,284 |
|
|
$ |
85,661 |
|
|
Schedule of Activity in Valuation Allowance Associated with Deferred taxes |
The activity in the valuation allowance associated with deferred taxes consists of the following:
(In thousands) |
|
Balance at Beginning of Period |
|
|
(Additions) / Reductions (1) |
|
|
Balance at
End of Period |
|
Deferred tax asset valuation allowance for the year ended December 31, 2019 |
|
$ |
(219,093 |
) |
|
$ |
(22,966 |
) |
|
$ |
(242,059 |
) |
Deferred tax asset valuation allowance for the year ended December 31, 2020 |
|
$ |
(242,059 |
) |
|
$ |
(11,590 |
) |
|
$ |
(253,649 |
) |
Deferred tax asset valuation allowance for the year ended December 31, 2021 |
|
$ |
(253,649 |
) |
|
$ |
4,537 |
|
|
$ |
(249,112 |
) |
(1) |
The (additions)/reductions in each of the periods presented relate primarily to Irish NOLs. Additionally, in 2019 the Company’s valuation allowance was increased by $3.0 million as a result of the attributes acquired as part of the acquisition of Rodin. |
|
Schedule of Reconciliation of Federal Statutory Tax Rate to its Effective Tax Rate |
A reconciliation of the Company’s statutory tax rate to its effective tax rate is as follows:
|
|
Year Ended December 31, |
|
|
(In thousands, except percentage amounts) |
|
2021 |
|
|
|
2020 |
|
|
|
2019 |
|
|
Statutory tax rate |
|
|
12.5 |
|
% |
|
|
12.5 |
|
% |
|
|
12.5 |
|
% |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Loss before income taxes at statutory rate |
|
$ |
(4,913 |
) |
|
|
$ |
(12,067 |
) |
|
|
$ |
(24,632 |
) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Share-based compensation |
|
|
7,841 |
|
|
|
|
8,972 |
|
|
|
|
6,287 |
|
|
Foreign rate differential(1) |
|
|
5,811 |
|
|
|
|
7,798 |
|
|
|
|
5,390 |
|
|
Change in valuation allowance |
|
|
(4,537 |
) |
|
|
|
11,590 |
|
|
|
|
19,882 |
|
|
Intercompany amounts(2) |
|
|
10,707 |
|
|
|
|
6,234 |
|
|
|
|
(1,125 |
) |
|
Irish rate differential(3) |
|
|
1,817 |
|
|
|
|
2,511 |
|
|
|
|
(146 |
) |
|
Uncertain tax positions |
|
|
704 |
|
|
|
|
811 |
|
|
|
|
776 |
|
|
Non deductible lobbying expenses |
|
|
637 |
|
|
|
|
683 |
|
|
|
|
736 |
|
|
U.S. state income taxes, net of U.S. federal benefit |
|
|
248 |
|
|
|
|
1,298 |
|
|
|
|
1,051 |
|
|
Federal tax law change(4) |
|
|
- |
|
|
|
|
248 |
|
|
|
|
(8,111 |
) |
|
In-process R&D(5) |
|
|
2,724 |
|
|
|
|
84 |
|
|
|
|
10,824 |
|
|
Foreign derived intangible income |
|
|
(3,875 |
) |
|
|
|
(3,125 |
) |
|
|
|
(3,450 |
) |
|
R&D credit |
|
|
(8,488 |
) |
|
|
|
(11,198 |
) |
|
|
|
(8,846 |
) |
|
Other permanent items(6) |
|
|
187 |
|
|
|
|
485 |
|
|
|
|
928 |
|
|
Income tax provision (benefit) |
|
$ |
8,863 |
|
|
|
$ |
14,324 |
|
|
|
$ |
(436 |
) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Effective tax rate |
|
|
(22.5 |
) |
% |
|
|
(14.8 |
) |
% |
|
|
0.2 |
|
% |
(1) |
Represents income or losses of non-Irish subsidiaries, including U.S. subsidiaries, subject to tax at a rate other than the Irish statutory rate. |
(2) |
Intercompany amounts include cross-territory eliminations, the pre-tax effect of which has been eliminated in arriving at the Company's consolidated loss before taxes. |
(3) |
Represents income or losses of Irish companies subject to tax at a rate other than the Irish statutory rate. |
(4) |
During the year ended December 31, 2019, federal tax law change represents federal income tax benefit related to the foreign derived intangible income deductions for 2018 following the publications by the IRS and the Department of Treasury of proposed regulations in March 2019. |
(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:
|
|
Unrecognized |
|
(In thousands) |
|
Tax Benefits |
|
Balance, December 31, 2018 |
|
$ |
6,081 |
|
Additions based on tax positions related to prior periods |
|
|
38 |
|
Additions based on tax positions related to the current period |
|
|
738 |
|
Balance, December 31, 2019 |
|
$ |
6,857 |
|
Additions based on tax positions related to prior periods |
|
|
15 |
|
Additions based on tax positions related to the current period |
|
|
796 |
|
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 |
|
|