In the Tax Cuts and Jobs Act (the Tax Act”) was enacted. The Tax Act significantly revised the U.S. corporate income tax regime by, among other things, the following items:

 

 

For the Successor period from to the Company recorded an income tax benefit of million, resulting in a effective tax rate. For the Predecessor period from to the Company recorded an income tax benefit of million, resulting in an effective tax rate of For the Predecessor period from to the Company recorded an income tax benefit of million. The effective tax rate for the Predecessor period from to was meaningful.

 

The year-over-year decrease in our effective tax rate when comparing the Predecessor period of to to both the Successor period from to and the Predecessor period from to was impacted by the following items:

 

 

At and we had deferred tax liabilities, net of deferred tax assets, of million and million, respectively. The increase in our net deferred tax liability is primarily due to deferred tax liabilities recorded in purchase accounting related to the fair value adjustments to fixed assets and other identifiable intangible assets.  The valuation allowances were related to foreign tax credit carryforwards where realization is more uncertain at this time due to the limited carryforward periods that exist.

 

The Company has liability for uncertain tax positions at and

 

The sources of income before income taxes for the years ended and are as follows:

 

		2018				2017				2016
United States		$	15,076,595			$	3,813,825			$	10,687,132
Foreign			3,521,127				856,112				-
Total		$	18,597,722			$	4,669,937			$	10,687,132

 

The components of the provision for income taxes for the years ended and are as follows:

 

		2018				2017				2016
Current tax provision:
Federal		$	(365,902	)		$	2,201,279			$	156,533
Foreign			1,232,718				378,031				-
State and local			455,537				578,697				542,378
Total current tax provision			1,322,353				3,158,007				698,911
Deferred tax provision (benefit):
Federal			(10,650,171	)			993,603				3,586,058
Foreign			(729,745	)			(132,607	)			-
State and local			273,443				(262,345	)			168,572
Total deferred tax (benefit) provision			(11,106,473	)			598,651				3,754,630
Net provision for income taxes		$	(9,784,120	)		$	3,756,658			$	4,453,541

 

For the years ended and the income tax provision differs from the expected tax provision computed by applying the U.S. federal statutory rate to income before taxes as a result of the following:

 

		2018				2017				2016
Provision for income taxes at blended U.S. statutory rate of 23.1% and 34.7%		$	4,309,576			$	1,587,778			$	3,633,625
State income taxes, net of federal deduction			560,056				285,982				469,227
Foreign rate differential			(178,927	)			(139,460	)			-
Meals and entertainment			220,234				270,789				234,353
Transaction costs			44,145				1,582,474				-
Change in deferred tax rate			-				(116,954	)			83,409
Domestic manufacturing deduction			-				(254,236	)			(189,453	)
Stock-based compensation			64,849				122,844				36,851
Contingent consideration fair value adjustment			122,077				-				-
Nontaxable Interest income net of foreign income inclusions			39,973				(378,068	)			-
Foreign tax credit			-				(79,791	)			-
Deferred tax on undistributed foreign earnings			(141,935	)			888,576				-
Impact of tax reform			(14,644,758	)			-				-
Increase in valuation allowance			-				52,662				-
Other			(179,410	)			(65,938	)			185,529
Income tax provision		$	(9,784,120	)		$	3,756,658			$	4,453,541

 

The tax effects of the temporary differences giving rise to the Company’s net deferred tax liabilities as of and are summarized as follows:

 

		2018				2017
Deferred tax assets:
Accrued insurance reserves		$	943,054			$	1,000,078
Accrued sales and use tax			961,863				997,091
Accrued payroll			367,653				509,276
Foreign tax credit carryforward			79,791				79,791
Net operating loss carryforward			1,930,998				160
Other			254,998				200,936
Total deferred tax assets			4,538,357				2,787,332
Valuation allowance			(63,035	)			(52,662	)
Net deferred tax assets			4,475,322				2,734,670
Deferred tax liabilities:
Intangible assets			(6,219,735	)			(11,879,983	)
Property and equipment			(36,394,087	)			(39,717,047	)
Prepaid expenses			(119,712	)			(352,976	)
Unremitted foreign earnings			(746,641	)			(888,576	)
Other			-				(7,414	)
Total net deferred tax liabilities			(43,480,175	)			(52,845,996	)
Net deferred tax assets		$	(39,004,853	)		$	(50,111,326	)

 

The Company has federal net operating loss carry forwards of for the period ended The Company did have any federal net operating loss carry forwards for the period ended The Company has state net operating loss carry forwards of approximately and respectively, as of and that begin to expire in

 

The Company has foreign tax credit carryforwards of approximately as of both and respectively, which begin to expire in

 

The Company has provided U.S. deferred taxes on cumulative earnings of all of its non-U.S. affiliates.

 

In assessing the realizability of deferred tax assets, management considers whether it is more likely than that some portion or all of the deferred tax assets will be realized. The ultimate realization of deferred tax assets is dependent upon the generation of future taxable income during the periods in which those temporary differences become deductible. Management considers the scheduled reversal of deferred tax liabilities, projected future taxable income, carryback opportunities, and tax planning strategies in making the assessment. The Company believes it is more likely than that it will realize the benefits of these deductible differences, net of the valuation allowance provided. The valuation allowance provided by the Company relates to foreign tax credit carry forwards.

 

In the Tax Cuts and Jobs Act (the Tax Act”) was enacted. The Tax Act significantly revised the U.S. corporate income tax regime by, among other things, lowering the U.S. corporate tax rate from  percent to  percent effective The Company recognized the income tax effects of the Tax Act in its consolidated financial statements in the period the Tax Act was signed into law.

 

The SEC staff recognized that entities have the necessary information available, prepared, or analyzed in reasonable detail to complete the accounting under ASC for certain income tax effects of the Tax Act in the reporting period that includes the date of enactment. In accordance with Staff Accounting Bulletin which provides SEC staff guidance for the application of ASC the Company’s consolidated financial statements for the period ended reflect the income tax effects of the Tax Act.

 

The Tax Act creates a requirement that certain income earned by controlled foreign corporations (“CFCs”) must be included currently in the gross income of the CFC's U.S. shareholder. The Global Intangible Low Tax Income (“GILTI”) provisions are effective for tax years beginning on or after In FASB staff Q&A Topic Accounting for Global Intangible Low-Taxed Income, the FASB staff noted that Accounting Standards Codification (“ASC”) (“Topic ), Income Taxes, was clear with respect to the appropriate accounting for GILTI, and accordingly, an entity either: () elect to treat taxes on GILTI as period costs similar to special deductions, or () recognize deferred tax assets and liabilities when basis differences exist that are expected to affect the amount of GILTI inclusion upon reversal (the deferred method). The Company has yet adopted an accounting policy related to GILTI.

 

As a result of the Tax Act, the Company recorded a tax benefit of for the period ended related to the remeasurement of deferred tax assets and liabilities to reflect the reduction in the U.S. corporate income tax rate from percent to percent. The Company also recorded a tax expense of for the period ended related to the deemed repatriation of earnings from its foreign subsidiaries, also known as the “Transition Tax”. The net of these adjustments related to the Tax Act reflect the total impact of tax reform for the period ended