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INCOME TAXES
 12 Months Ended
Dec. 31, 2023
Income Tax Disclosure [Abstract]  
INCOME TAXES INCOME TAXES
The current and deferred components of the income tax (benefit) provision included in the Consolidated Statements of Operations are as follows:
 
Year Ended December 31,
202320222021
Current:
Cayman Islands$— $— $— 
Bermuda— — — 
United States:
Federal935 522 1,850 
State and local1,176 1,687 760 
Other Non-U.S.1,715 443 (11)
Total current provision3,826 2,652 2,599 
Deferred:
Cayman Islands— — — 
Bermuda(72,185)— — 
United States:
Federal3,943 1,305 126 
State and local(2)242 122 
Other Non-U.S.4,618 1,101 279 
Total deferred (benefit) provision(63,626)2,648 527 
Provision for (benefit from) income taxes:
Continuing operations(59,800)5,300 3,126 
Discontinued operations— 8,227 (4,183)
Total$(59,800)$13,527 $(1,057)

The Company is an exempted entity domiciled in the Cayman Islands where income taxes are not imposed. The Company is considered a Passive Foreign Investment Company for U.S. income tax purposes and certain income taxes are imposed on our owners. Taxable income or loss generated by our corporate subsidiaries is subject to U.S. federal, state and foreign corporate income tax in locations where they conduct business.
Historically, the Company’s Bermuda operations have not been subject to Bermuda income tax. However, on December 27, 2023, the Government of Bermuda enacted a 15% corporate income tax regime (the “Bermuda CIT”) that applies to Bermuda businesses that are part of multinational enterprise groups with annual revenue of €750 million or more and is effective for tax years beginning on or after January 1, 2025. As a result of the Bermuda CIT, the exemption of certain of the Company’s Bermuda subsidiaries from Bermuda corporate income taxes will cease in 2025. With the enactment of the Bermuda CIT in 2023, the Company underwent an analysis to determine the tax impacts to its consolidated financial statements for the year ended December 31, 2023. We have recorded a deferred tax asset of $72.2 million in connection with the law change, which was recorded as a benefit from income taxes.
The difference between our reported total provision for income taxes and the Cayman Islands statutory rate of 0% is as follows:
 
Year Ended December 31,
202320222021
Income subject to tax in the United States3.3 %(6.9)%(7.2)%
Foreign taxes(30.9)%13.5 %(8.7)%
Change in valuation allowance (4.9)%(11.6)%8.0 %
Provision for income taxes(32.5)%(5.0)%(7.9)%

Significant components of our deferred tax assets and liabilities are as follows:
December 31,
20232022
Deferred tax assets:
Net operating loss carryforwards$38,911 $43,116 
Interest expense1,861 2,754 
Investment in Partnerships963 963 
Inventory 16,985 — 
Customer Relationship Intangibles 28,500 — 
Other— 272 
Total deferred tax assets87,220 47,105 
Less valuation allowance(18,599)(27,565)
Net deferred tax assets68,621 19,540 
Deferred tax liabilities:
Fixed assets and goodwill(8,186)(22,794)
Other(63)
Net deferred tax assets (liabilities)$60,372 $(3,254)

Deferred tax assets and liabilities are reported net in Other assets or Other liabilities in the Consolidated Balance Sheets. In assessing the realizability of deferred tax assets, management considers whether it is more likely than not that some portion or all of the deferred tax assets will not be realized. The ultimate realization of deferred tax assets is dependent upon the generation of future taxable income during the periods in which temporary differences become deductible. We have analyzed our deferred tax assets and have determined, based on the weight of available evidence, that it is more likely than not that a significant portion will not be realized. Accordingly, valuation allowances have been recognized as of December 31, 2023, 2022 and 2021 of $18.6 million, $27.6 million and $9.1 million, respectively, related to certain deductible temporary differences and net operating loss carryforwards.
A summary of the changes in the valuation allowance is as follows:
December 31,
202320222021
Valuation allowance at beginning of period$27,565 $9,142 $6,794 
Change due to current year losses855 22,094 2,356 
Change due to current year releases(9,821)(3,671)(8)
Valuation allowance at end of period$18,599 $27,565 $9,142 
As of December 31, 2023, certain of our corporate subsidiaries had U.S. federal net operating loss carryforwards of approximately $22.8 million which can be carried forward indefinitely against future business income. As of December 31, 2023, we also had net operating loss carryforwards for Irish income tax purposes of $266.4 million, which can be carried forward indefinitely against future business income, $1.6 million of net operating loss carryforwards for Malaysian income tax purposes, which will begin to expire in the year 2030, and $2.1 million of net operating loss carryforward for Singaporean income tax purpose, which can be carried forward indefinitely against the future business income. The utilization of the net operating loss carryforwards to reduce future income taxes will depend on the relevant corporate subsidiary's ability to generate sufficient taxable income prior to the expiration of the carryforward period, if any. In addition, the maximum annual use of net operating loss carryforwards may be limited after certain changes in share ownership.
As of and for the period ended December 31, 2023, we had not established a liability for uncertain tax positions as no such positions existed. In general, our tax returns and the tax returns of our corporate subsidiaries are subject to U.S. federal, state, local and foreign income tax examinations by tax authorities. Generally, we are not subject to examination by taxing authorities for tax years prior to 2019. We do not believe that it is reasonably possible that the total amount of unrecognized tax benefits will significantly change within 12 months of the reporting date.