v3.25.2
Income and Mining Taxes
 6 Months Ended
Jun. 30, 2025
Income Tax Disclosure [Abstract]  
INCOME AND MINING TAXES INCOME AND MINING TAXES
    The following table summarizes the components of Income and mining tax (expense) benefit for the three and six months ended June 30, 2025 and 2024 by significant jurisdiction:
Three months ended June 30,Six months ended June 30,
 2025202420252024
In thousandsIncome (loss) before taxTax (expense) benefitIncome (loss) before taxTax (expense) benefitIncome (loss) before taxTax (expense) benefitIncome (loss) before taxTax (expense) benefit
United States$82,138 $(15,229)$(4,660)$1,677 $102,463 $(20,534)$(33,890)$(2,142)
Canada(15,099)(693)(9,628)(258)(25,051)(811)(18,535)(372)
Mexico66,879 (46,673)22,948 (8,608)107,969 (59,663)48,152 (20,699)
Other jurisdictions(597)— (45)— (294)— (205)— 
$133,321 $(62,595)$8,615 $(7,189)$185,087 $(81,008)$(4,478)$(23,213)
    During the second quarter of 2025, the Company reported estimated income and mining tax expense of approximately $62.6 million, resulting in an effective tax rate of 47.0%. This compares to income tax expense of $7.2 million for an effective tax rate of 83.4% during the second quarter of 2024. The comparability of the Company’s income and mining tax (expense) benefit and effective tax rate for the reported periods was impacted by multiple factors, primarily: (i) variations in our income before income taxes; (ii) geographic distribution of that income; (iii) foreign exchange rates; (iv) mining taxes; (v) the impact of uncertain tax positions; and (vi) percentage depletion. Fluctuations in foreign exchange rates on deferred tax balances increased income and mining tax expense by $28.3 million and decreased income and mining tax expense by $0.9 million for the three months ended June 30, 2025 and 2024, respectively. The impact of foreign exchange rates on deferred tax balances is predominantly due to the Mexican Peso and deferred taxes resulting from Las Chispas purchase price accounting. Therefore, the effective tax rate will fluctuate, sometimes significantly, period to period.
A valuation allowance is provided for deferred tax assets for which it is more likely than not that the related tax benefits will not be realized. The Company analyzes its deferred tax assets and, if it is determined that the Company will not realize all or a portion of its deferred tax assets, it will record or increase a valuation allowance. Conversely, if it is determined that the Company ultimately will be more likely than not able to realize all or a portion of the related benefits for which a valuation allowance has been provided, all or a portion of the related valuation allowance will be reduced. There are a number of factors that impact the Company’s ability to realize its deferred tax assets. For additional information, please see the section titled “Item 1A - Risk Factors” in the 2024 10-K.
The Company or one of its subsidiaries files income tax returns in the U.S. federal and state jurisdictions, in all identified foreign jurisdictions, and various others. The statute of limitations remains open from 2021 for the U.S. federal jurisdiction, for 2016 and from 2020 for the Mexico federal jurisdiction, and from 2018 for certain other foreign jurisdictions. Our 2016 federal tax return is currently under audit in Mexico. As a result of the statutes of limitation that will begin to expire within the next 12 months in various jurisdictions and possible settlements of audit-related issues with taxing authorities in various jurisdictions with respect to which none of the issues are individually significant, the Company believes that it is reasonably possible that the total amount of its net unrecognized income tax benefits will decrease between $2.2 and $2.7 million in the next twelve months.
At June 30, 2025 and December 31, 2024, the Company had $17.5 million and $0.0 million of total gross unrecognized tax benefits, respectively, that, if recognized, would positively impact the Company’s effective income tax rate. The Company’s continuing practice is to recognize potential interest and/or penalties related to unrecognized tax benefits as part of its income tax expense. At June 30, 2025 and December 31, 2024, the amount of accrued income-tax-related interest and penalties was $4.8 million and $0.0 million, respectively.
In 2021, the Organization for Economic Co-operation and Development (OECD) published Pillar Two Model Rules defining a global minimum tax, which calls for the taxation of large corporations at a minimum rate of 15%. The OECD has since issued administrative guidance providing transition and safe harbor rules around the implementation of the Pillar Two global minimum tax. Effective January 1, 2024, a number of countries have proposed or enacted legislation to implement core elements of the Pillar Two proposal. The Company’s worldwide revenues did not exceed the thresholds necessary to be subject to the Pillar Two rules during its year ended December 31, 2024.
As a result of 2025 business expansions, including the first quarter of 2025 closing of acquisition of SilverCrest Metals Inc., the Company expects to fall within the scope of the Pillar Two rules from January 1, 2025. The Company will continue to monitor developments and evaluate the potential impact on 2025 and future periods. At this time, based on the Company’s current analysis of the Pillar Two provisions and because the Company primarily does business in jurisdictions with a tax rate greater than 15%, the Company does not anticipate a material impact to its Consolidated Financial Statements.
On July 4, 2025, the One Big Beautiful Bill Act (“OBBBA”) was signed into law, extending key provisions of the 2017 Tax Cuts and Jobs Act including, but not limited to, federal bonus depreciation and deductions for domestic research and development expenditures. The Company is currently evaluating OBBBA; however, it is not expected to have a material impact on the Company’s consolidated financial statements.