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 in continuing operations as the credits remain with Rayonier after the spin-off, related to its limited potential use of the CBPC prior to its expiration on December 31, 2016. During the third quarter of 2014, the Company reversed $1 million of the valuation allowance due to an estimated increase in its ability to use the CBPC.

Provision for Income Taxes from Continuing Operations

The Company’s effective tax rate 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.

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



	Three Months Ended September 30,
	2014					2013
Income tax expense at federal statutory rate	$	7,273		35.0	%	$	2,881		35.0	%
REIT income, taxable losses and other	(16,673		)	(80.2	)	(10,094		)	(122.6	)
Foreign operations	(44		)	(0.2	)	1,295			15.8
Loss on early redemption of Senior Exchangeable Notes	—			—		288			3.5
Other	99			0.4		(33		)	(0.5	)
Income tax benefit before discrete items	(9,345		)	(45.0	)%	(5,663		)	(68.8	)%
Uncertain tax positions	(1,830		)	(8.8	)	(800		)	(9.7	)
CBPC valuation allowance	(990		)	(4.8	)	—			—
Return to accrual adjustments	885			4.3		—			—
Other	—			—		(345		)	(4.2	)
Income tax benefit as reported for continuing operations	$	(11,280	)	(54.3	)%	$	(6,808	)	(82.7	)%



	Nine Months Ended September 30,
	2014					2013
Income tax expense at federal statutory rate	$	14,385		35.0	%	$	15,732		35.0	%
REIT income and taxable losses	(30,572		)	(74.4	)	(41,417		)	(92.1	)
Foreign operations	(88		)	(0.2	)	2,812			6.3
Loss on early redemption of Senior Exchangeable Notes	—			—		1,572			3.5
Other	196			0.5		(185		)	(0.4	)
Income tax benefit before discrete items	(16,079		)	(39.1	)%	(21,486		)	(47.7	)%
CBPC valuation allowance	14,584			35.5		—			—
Deferred tax inventory valuations	(3,293		)	(8.0	)	—			—
Uncertain tax positions	(1,830		)	(4.5	)	—			—
Spin-off related costs	797			1.9		—			—
Return to accrual adjustments	885			2.2		—			—
Gain related to consolidation of New Zealand joint venture	—			—		(5,634		)	(12.5	)
Reversal of REIT BIG tax payable	—			—		(485		)	(1.1	)
Other	(383		)	(0.9	)	(1,145		)	(2.6	)
Income tax benefit as reported for continuing operations	$	(5,319	)	(12.9	)%	$	(28,750	)	(63.9	)%

Provision for Income Taxes from Discontinued Operations

On June 27, 2014, Rayonier completed the spin-off of its Performance Fibers business. For the three and nine months ended September 30, 2014, income tax expense related to Performance Fibers discontinued operations was $0 and $21.2 million, respectively. For the three and nine months ended September 30, 2013, income tax expense related to Performance Fibers discontinued operations was $18.3 million and $59.9 million, respectively.

On March 1, 2013, Rayonier completed the sale of its Wood Products business for $80 million plus a working capital adjustment. For the nine months ended September 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 the third quarter of 2014, the Company removed a $5.8 million unrecognized tax benefit liability due to the expiration of the statute of limitations on examination of its 2010 tax return. This resulted in a $1.8 million income tax benefit and a $4.0 million reduction of a non-current tax asset. There are no unrecognized tax benefit liabilities remaining as of September 30, 2014.

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 included a $0.9 million unrecognized tax benefit, which was recorded in discontinued operations.

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 $4.2 million as of September 30, 2014. The remaining balance reflects the $14.6 million valuation allowance related to Rayonier’s limited potential use of the CBPC credit.