INCOME TAXES

12 Months Ended

Dec. 31, 2021

Income Tax Disclosure [Abstract]

INCOME TAXES

NOTE 3—INCOME TAXES

U.S. and foreign earnings before income taxes are as follows:

	Years Ended December 31,
	2021		2020		2019
	(In thousands)
U.S.	$	184,835	$	547,969	$	454,036
Foreign	71,313		82,983		78,384
Total	$	256,148	$	630,952	$	532,420

The components of the provision (benefit) for income taxes are as follows:

	Years Ended December 31,
	2021		2020		2019
	(In thousands)
Current income tax provision (benefit):
Federal	$	15	$	(2,044)	$	964
State	3,192		1,640		342
Foreign	34,865		28,293		26,527
Current income tax provision	38,072		27,889		27,833
Deferred income tax provision (benefit):
Federal	(32,723)		31,025		(2,159)
State	(18,627)		(10,451)		(9,698)
Foreign	(6,619)		(5,190)		(896)
Deferred income tax (benefit) provision	(57,969)		15,384		(12,753)
Income tax (benefit) provision	$	(19,897)	$	43,273	$	15,080

The tax effects of cumulative temporary differences that give rise to significant portions of the deferred tax assets and deferred tax liabilities are presented below. The valuation allowance is primarily related to deferred tax assets for foreign net operating losses and U.S. foreign tax credits.

	December 31,
	2021		2020
	(In thousands)
Deferred tax assets:
Net operating loss carryforwards	$	85,613	$	152,346
Tax credit carryforwards	128,731		102,012
Disallowed interest carryforwards	52,104		56,630
Stock-based compensation	15,491		16,073
Accrued expenses	116,415		9,283
Exchangeable notes	52,177		64,212
Other	33,211		25,532
Total deferred tax assets	483,742		426,088
Less valuation allowance	(86,071)		(71,090)
Net deferred tax assets	397,671		354,998
Deferred tax liabilities:
Intangible assets	(165,551)		(44,200)
Right-of-use assets	(21,784)		(17,306)
Property and equipment	(4,923)		(17,218)
Other	(737)		—
Total deferred tax liabilities	(192,995)		(78,724)
Net deferred tax assets	$	204,676	$	276,274

The Company’s tax group for federal and consolidated state income tax purposes includes Former IAC up to and including the Separation date. As a result of the Separation, the Company’s net deferred tax asset was adjusted via additional paid-in capital for tax attributes allocated to Match Group from our consolidated federal and state income tax returns. A preliminary allocation was recorded as of June 30, 2020. The final adjustment

recorded in 2021 as a result of filing the 2020 consolidated federal and state income tax returns was not significant.

At December 31, 2021, the Company has federal and state net operating losses (“NOLs”) of $174.1 million and $276.5 million, respectively. If not utilized, $17.3 million of the federal NOLs can be carried forward indefinitely, and $156.8 million will expire at various times between 2031 and 2037. Of the state NOLs, $3.8 million can be carried forward indefinitely and $272.7 million will expire at various times between 2024 and 2041. Federal and state NOLs of $142.6 million and $252.1 million, respectively, can be used against future taxable income without restriction and the remaining NOLs will be subject to limitations under Section 382 of the Internal Revenue Code, separate return limitations, federal taxable income limitations, and applicable state law. At December 31, 2021, the Company has foreign NOLs of $131.9 million available to offset future income. Of these foreign NOLs, $99.6 million can be carried forward indefinitely and $32.3 million will expire at various times between 2022 and 2038. During 2021, the Company recognized tax benefits related to NOLs of $2.2 million. At December 31, 2021, the Company has federal and foreign disallowed interest carryforwards of $154.6 million and $69.4 million, respectively, that can be carried forward indefinitely and can be used against future taxable income.

At December 31, 2021, the Company has tax credit carryforwards of $162.7 million. Of this amount, $125.1 million relates to federal and state tax credits for research activities, of which $80.8 million will expire at various times between 2033 and 2041. Our credit carryforwards also include $37.0 million of foreign tax credits, of which $35.1 million will expire primarily in 2027.

The Company regularly assesses the realizability of deferred tax assets considering all available evidence, including, to the extent applicable, the nature, frequency and severity of prior cumulative losses, forecasts of future taxable income, tax filing status, the duration of statutory carryforward periods, available tax planning and historical experience.

During the year ended December 31, 2021, we recorded an increase to the valuation allowance of $15.0 million primarily related to foreign losses for which we do not believe a tax benefit is more likely than not to be realized. At December 31, 2021, the Company had a valuation allowance of $86.1 million related to the portion of credits, NOLs, and other deferred tax assets for which it is more likely than not that the tax benefit will not be realized.

A reconciliation of the income tax provision to the amounts computed by applying the statutory federal income tax rate to earnings before income taxes is shown as follows:

	Years Ended December 31,
	2021		2020		2019
	(In thousands)
Income tax provision at the federal statutory rate of 21%	$	53,791	$	132,500	$	111,808
State income taxes, net of effect of federal tax benefit	4,530		8,803		10,274
Stock-based compensation	(63,751)		(112,203)		(90,374)
Research credits	(25,830)		(21,306)		(27,248)
Change in valuation allowance	8,523		29,787		—
Foreign income taxed at a different statutory rate	5,808		4,884		3,526
Withholding taxes	1,057		2,933		5,023
Change in uncertain tax positions	(948)		(5,770)		(637)
Other, net	(3,077)		3,645		2,708
Income tax (benefit) provision	$	(19,897)	$	43,273	$	15,080

A reconciliation of the beginning and ending amount of unrecognized tax benefits, including penalties but excluding interest, is as follows:

	December 31,
	2021		2020		2019
	(In thousands)
Balance at January 1	$	45,624	$	53,324	$	35,679
Additions based on tax positions related to the current year	8,107		7,818		11,221
Additions for tax positions of prior years	1,353		1,772		7,599
Reductions for tax positions of prior years	(1,028)		—		(283)
Settlements	(2,348)		(16,512)		—
Expiration of applicable statute of limitations	(878)		(778)		(892)
Balance at December 31	$	50,830	$	45,624	$	53,324

The Company recognizes interest and, if applicable, penalties related to unrecognized tax benefits in the income tax provision. Our income tax provision, for the years ended December 31, 2021, 2020, and 2019, includes a (decrease) or increase of interest and penalties of $(0.3) million, $(1.7) million, and $0.1 million, respectively. At December 31, 2021 and 2020, noncurrent income taxes payable include accrued interest and penalties of $1.5 million and $1.9 million, respectively.

Match Group is routinely under audit by federal, state, local and foreign authorities in the area of income tax. These audits include questioning the timing and the amount of income and deductions and the allocation of income and deductions among various tax jurisdictions. The Internal Revenue Service (“IRS”) has substantially completed its audit of the Company’s federal income tax returns for the years ended December 31, 2013 through 2017 and has begun its audit of the years ended December 31, 2018 and 2019. The statute of limitations for years 2013 through 2019 has been extended to December 31, 2023. We are no longer subject to U.S. federal income tax examinations for years prior to 2013. Returns filed in various other jurisdictions are open to examination for tax years beginning with 2009. Although we believe that we have adequately reserved for our uncertain tax positions, the final tax outcome of these matters may vary significantly from our estimates.

At December 31, 2021 and 2020, unrecognized tax benefits, including interest, were $51.8 million and $46.7 million, respectively. If unrecognized tax benefits at December 31, 2021 are subsequently recognized, $46.0 million, net of related deferred tax assets and interest, would reduce income tax expense. The comparable amount as of December 31, 2020 was $41.8 million. The Company believes that it is reasonably possible that its unrecognized tax benefits could decrease by approximately $0.9 million by December 31, 2022, primarily due to settlements and expirations of statutes of limitations.

Generally, our ability to distribute the $172.7 million cash and cash equivalents held by our foreign subsidiaries at December 31, 2021 is limited to that subsidiary’s distributable reserves and after considering other corporate legal restrictions. Our earnings in foreign jurisdictions are generally available for distribution to the U.S. without significant tax consequences.