5. Income taxes: The components of loss before income taxes consist of the following (in thousands): | | | | | | | | | | | | | | | Three Months Ended | | Three Months Ended | | Six Months Ended | | Six Months Ended | | | June 30, 2025 | | June 30, 2024 | | June 30, 2025 | | June 30, 2024 | Domestic | | $ | (73,645) | | $ | (37,199) | | $ | (136,219) | | $ | (116,203) | Foreign | | | (880) | | | (2,992) | | | (8,569) | | | (8,422) | Total | | $ | (74,525) | | $ | (40,191) | | $ | (144,788) | | $ | (124,625) |
On July 4, 2025, H. R. 1 (the “2025 Tax Act”) was enacted into law. The legislation includes several significant provisions affecting the taxation of domestic and international business operations, including: | ● | Permanent extension of 100% bonus depreciation for qualified property placed in service after January 19, 2025. |
| ● | Changes to the interest expense limitation under Section 163(j), which includes depreciation and amortization in the calculation of adjusted taxable income thus increasing this base, and effective for tax years beginning after December 31, 2024. This change results in a higher limitation threshold and potentially reduces disallowed interest expense in future periods. |
| ● | Modifications to the GILTI regime, now referred to as Net CFC Tested Income (“NCTI”), including the elimination of the deemed 10% on QBAI and reduction in the Section 250 deduction. |
| ● | Replacement of FDII with a new Foreign Derived Domestic Eligible Income (“FDDEI”) regime, modifying the deduction rate and simplifying the overall calculation. |
Under ASC 740, the income tax effects of the 2025 Tax Act will be recognized in the period of enactment. The Company expects the 2025 Tax Act to affect the valuation of certain of its deferred income taxes – a total net deferred income tax liability of $362.5 million at June 30, 2025. The Company is in the process quantifying this impact that will be recorded in the third quarter of 2025.
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