INCOME TAXES

Rayonier is a real estate investment trust (“REIT”). In general, only its taxable REIT subsidiaries, whose businesses include the Company’s non-REIT qualifying activities, and foreign operations, are subject to corporate income taxes. Accordingly, the provision for corporate income taxes relates principally to current and deferred taxes on taxable REIT subsidiaries’ income and foreign operations.

Alternative Fuel Mixture Credit (“AFMC”) and Cellulosic Biofuel Producer Credit (“CBPC”)

The U.S. Internal Revenue Code allowed two credits for taxpayers that produced and used an alternative fuel in the operation of their business through December 31, 2009. The AFMC is a $.50 per gallon refundable tax credit (which is not taxable), while the CBPC is a $1.01 per gallon credit that is nonrefundable, taxable and has limitations based on an entity’s tax liability. Prior to the spin-off (See Note 2 — Discontinued Operations for additional information), Rayonier produced and used an alternative fuel (“black liquor”) at its Performance Fibers mills, which qualified for both credits. The Company claimed the AFMC on its original 2009 tax return. In the first quarter of 2013, management approved a $70 million tax payment to exchange approximately 120 million gallons of black liquor previously claimed for the AFMC for the CBPC, resulting in an expected net $19 million tax benefit, which was recorded in discontinued operations. As a result of the spin-off of the Performance Fibers business in second quarter 2014, the Company recorded a $16 million valuation allowance related to its limited potential use of the CBPC prior to its expiration on December 31, 2016.

Provision for Income Taxes from Continuing Operations

The Company’s effective tax rate before discrete items is below the 35 percent U.S. statutory rate due to tax benefits associated with being a REIT and tax benefits from losses at Rayonier's taxable operations from interest and general administrative expenses not allowed to be allocated to the discontinued operations of the Performance Fibers business. Despite the tax benefits associated with being a REIT and losses at Rayonier’s taxable operations, the increase in the effective tax rates as reported for the quarter and year-to-date periods is primarily attributable to the CBPC valuation allowance recorded in second quarter 2014.

The tables below reconcile the U.S. statutory rate to the Company’s effective tax rate for each period presented:



	Three Months Ended June 30,
	2014					2013
Income tax expense at federal statutory rate	$	6,850		35.0	%	$	8,289		35.0	%
REIT income and taxable losses	(7,382		)	(37.7	)	(20,001		)	(84.4	)
Reverse loss on FMV of exchangeable notes	—			—		828			3.5
Foreign operations	(688		)	(3.5	)	458			1.9
Non-deductible real estate losses	558			2.8		—			—
Other	112			0.6		115			0.5
Income tax benefit before discrete items	(550		)	(2.8	)%	(10,311		)	(43.5	)%
CBPC valuation allowance	15,574			79.7		—			—
Spin-off related costs	797			4.1		—			—
Deferred tax inventory valuations	(3,293		)	(16.8	)	—			—
Gain related to consolidation of New Zealand joint venture	—			—		(5,636		)	(23.8	)
Other	987			4.9		—			—
Income tax expense (benefit) as reported for continuing operations	$	13,515		69.1	%	$	(15,947	)	(67.3	)%



	Six Months Ended June 30,
	2014					2013
Income tax expense at federal statutory rate	$	8,498		35.0	%	$	12,851		35.0	%
REIT income and taxable losses	(15,230		)	(62.7	)	(31,324		)	(85.3	)
Foreign operations	(854		)	(3.5	)	1,517			4.1
Non-deductible real estate losses	692			2.8		—			—
Reverse loss on FMV of exchangeable notes	—			—		1,284			3.5
Other	139			0.6		(151		)	(0.4	)
Income tax benefit before discrete items	(6,755		)	(27.8	)%	(15,823		)	(43.1	)%
CBPC valuation allowance	15,574			64.1		—			—
Spin-off related costs	797			3.3		—			—
Deferred tax inventory valuations	(3,293		)	(13.6	)	—			—
Gain related to consolidation of New Zealand joint venture	—			—		(5,636		)	(15.3	)
Other	(384		)	(1.5	)	(483		)	(1.4	)
Income tax expense (benefit) as reported for continuing operations	$	5,939		24.5	%	$	(21,942	)	(59.8	)%

Provision for Income Taxes from Discontinued Operations

In second quarter 2014, Rayonier completed the spin-off of its Performance Fibers business. For the three and six months ended June 30, 2014, income tax expense related to Performance Fibers discontinued operations was $6.0 million and $21.2 million, respectively. For the three and six months ended June 30, 2013, income tax expense related to Performance Fibers discontinued operations was $31.2 million and $41.6 million, respectively.

In first quarter 2013, Rayonier completed the sale of its Wood Products business for $80 million plus a working capital adjustment. For the six months ended June 30, 2013, income tax expense related to Wood Products discontinued operations was $22.3 million ($21.4 million from the gain on sale).

See Note 2 — Discontinued Operations for additional information on the spin-off of the Performance Fibers business and sale of the Wood Products business.

Unrecognized Tax Benefits

During second quarter 2014, the Company received a refund from the IRS related to its amended 2009 TRS tax return. As a result, Rayonier reversed the $4.8 million reserve related to the increased domestic production deduction due to the inclusion of CBPC income. The reserve was comprised of a $3.9 million reduction of current deferred tax assets and a $0.9 million unrecognized tax benefit, which was recorded in discontinued operations.

During the first quarter of 2013, the Company implemented ASU 2013-11, which requires, in certain instances, an unrecognized tax benefit (or portion of an unrecognized tax benefit) to be presented in the financial statements as a reduction to a deferred tax asset for a net operating loss carryforward, a similar tax loss or a tax credit carryforward. As a result, the Company reclassified $3.9 million from an unrecognized tax benefit liability to a reduction to current deferred tax assets at March 31, 2014.

Deferred Taxes

The spin-off of the Performance Fibers business resulted in the contribution of deferred tax assets and deferred tax liabilities to Rayonier Advanced Materials and impacted the Company’s expected future use of remaining deferred tax assets. The Company’s current portion of deferred tax assets decreased from $39.1 million at December 31, 2013 to $3.2 million as of June 30, 2014. The remaining balance reflects the $15.6 million valuation allowance related to Rayonier’s limited potential use of the CBPC credit. In addition, the Company’s non-current deferred tax asset decreased $3.0 million from year-end while the non-current deferred tax liability increased $8.7 million.