Income Taxes (Tables)
|
12 Months Ended |
Dec. 31, 2024 |
Income Taxes [Abstract] |
|
Schedule of Continuing Operations Before Income Taxes |
The below table presents
the jurisdictional composition of our income from continuing operations before income taxes for the years ended December 31, 2024,
2023 and 2022:
| |
2024 | | |
2023 | | |
2022 | |
United States | |
$ | 38,850,319 | | |
$ | 15,544,735 | | |
$ | 53,794,019 | |
Non-US | |
| (50,900,894 | ) | |
| 4,633,359 | | |
| 11,891,477 | |
(Loss) income from continuing operations,
before income taxes | |
$ | (12,050,575 | ) | |
$ | 20,178,094 | | |
$ | 65,685,496 | |
|
Schedule of Current and Deferred Tax Expense |
For the years ended December 31,
2024, 2023 and 2022, the current and deferred tax expense allocated to continuing operations were as follows:
| |
2024 | | |
2023 | | |
2022 | |
Current: | |
| | |
| | |
| |
US Federal | |
$ | 12,771,794 | | |
$ | 5,663,364 | | |
$ | 13,270,683 | |
US State | |
| 5,022,876 | | |
| 2,928,137 | | |
| 3,311,355 | |
Non-US | |
| 3,772,288 | | |
| 8,632,303 | | |
| 21,057,369 | |
Total current tax expense | |
| 21,566,958 | | |
| 17,223,804 | | |
| 37,639,407 | |
| |
| | | |
| | | |
| | |
Deferred: | |
| | | |
| | | |
| | |
US Federal | |
| (3,750,091 | ) | |
| (863,989 | ) | |
| (2,402,855 | ) |
US State | |
| (1,074,479 | ) | |
| (281,452 | ) | |
| (428,427 | ) |
Non-US | |
| (2,919,033 | ) | |
| 62,208 | | |
| (2,596,598 | ) |
Total deferred tax expense | |
| (7,743,603 | ) | |
| (1,083,233 | ) | |
| (5,427,880 | ) |
Total provision for income taxes | |
$ | 13,823,355 | | |
$ | 16,140,571 | | |
$ | 32,211,527 | |
|
Schedule of Tax Rate Reconciliation |
A reconciliation between the income tax expense
computed by applying the Cayman Island’s statutory income tax rate of 0% to income from continuing operations before income taxes
and actual income tax expense were as follows:
| |
2024 | | |
2023 | | |
2022 | |
Cayman Island income tax at statutory rate | |
| – | % | |
| – | % | |
| – | % |
| |
| | | |
| | | |
| | |
Effect of rates different than statutory | |
| | | |
| | | |
| | |
Australia | |
| 7.21 | % | |
| (22.78 | )% | |
| (0.44 | )% |
Brazil | |
| 9.02 | % | |
| (0.97 | )% | |
| – | % |
Canada | |
| 17.16 | % | |
| (0.44 | )% | |
| – | % |
Hong Kong | |
| 21.61 | % | |
| (14.89 | )% | |
| (7.84 | )% |
Japan | |
| 18.69 | % | |
| (13.85 | )% | |
| (1.30 | )% |
Mainland China | |
| (28.36 | )% | |
| 23.53 | % | |
| 31.40 | % |
Mexico | |
| 18.61 | % | |
| (0.04 | )% | |
| – | % |
Singapore | |
| 32.61 | % | |
| 16.91 | % | |
| (3.18 | )% |
United States - Federal | |
| (70.76 | )% | |
| 23.56 | % | |
| 19.20 | % |
United States - State | |
| (15.85 | )% | |
| 5.20 | % | |
| 3.15 | % |
Other countries | |
| 21.07 | % | |
| (8.15 | )% | |
| (1.21 | )% |
Change in valuation allowance | |
| (134.41 | )% | |
| 50.44 | % | |
| 4.20 | % |
Change in unrecognized tax benefit | |
| (15.50 | )% | |
| 8.83 | % | |
| 7.68 | % |
Return to provision differences - United States Federal | |
| (7.63 | )% | |
| 6.55 | % | |
| 1.46 | % |
Other | |
| 11.82 | % | |
| 6.08 | % | |
| (4.09 | )% |
Total | |
| (114.71 | )% | |
| 79.98 | % | |
| 49.03 | % |
|
Schedule of Deferred Tax Assets and Liabilities |
The significant components of the deferred tax assets and liabilities are as follows:
| |
2024 | | |
2023 | |
Deferred tax assets | |
| | |
| |
Net operating loss carryforwards | |
$ | 36,533,676 | | |
$ | 20,536,474 | |
Compensation accruals | |
| 9,058,023 | | |
| 4,771,220 | |
Lease liabilities | |
| 3,022,320 | | |
| 2,456,883 | |
Other | |
| 1,921,076 | | |
| 987,996 | |
Total deferred tax assets | |
| 50,535,095 | | |
| 28,752,573 | |
Less: valuation allowance | |
| (34,628,089 | ) | |
| (21,043,136 | ) |
Deferred tax assets, net of valuation allowance | |
| 15,907,006 | | |
| 7,709,437 | |
| |
| | | |
| | |
Deferred tax liabilities | |
| | | |
| | |
Right of use assets | |
| (2,704,189 | ) | |
| (2,154,329 | ) |
Intangibles | |
| (5,233,634 | ) | |
| (5,712,800 | ) |
Property and equipment | |
| (886,939 | ) | |
| (968,015 | ) |
Total deferred tax liabilities | |
| (8,824,762 | ) | |
| (8,835,144 | ) |
| |
| | | |
| | |
Net deferred tax asset | |
$ | 7,082,244 | | |
$ | (1,125,707 | ) |
|
Schedule of Income Tax Net Operating Loss Carryforwards |
The below table presents the expiration of our
net operating losses by jurisdiction as of December 31, 2024: Jurisdiction | | Net Operating Loss Carryforwards | | | Expiration | | Australia | | $ | 17,526,497 | | | | Indefinite | | Brazil | | | 3,294,408 | | | | Indefinite | | Canada | | | 9,219,682 | | | | 2041 - 2044 | | Hong Kong | | | 22,335,355 | | | | Indefinite | | Japan | | | 30,001,355 | | | | 2025 - 2024 | | Mainland China | | | 1,260,186 | | | | 2027 - 2029 | | Mexico | | | 14,650,709 | | | | 2031 - 2044 | | Singapore | | | 30,833,631 | | | | Indefinite | | United Kingdom | | | 7,175,137 | | | | Indefinite | | United States – Federal | | | 431,676 | | | | Indefinite | | Others | | | 13,347,741 | | | | * | | Total | | $ | 150,076,377 | | | | | |
| * | Of the other foreign net operating loss carryforwards, $11,581,596 expires between 2027 and 2034 and $1,766,145 have an indefinite expiration term. |
|
Schedule of Unrecognized Tax Benefits |
The following is a rollforward
of our unrecognized tax benefits as of December 31, 2024:
Total unrecognized tax benefit – January
1, 2023 | |
$ | 18,101,120 | |
Increase for prior year tax positions | |
| 180,919 | |
Increase for year 2023 tax positions | |
| 1,808,018 | |
Settlements with taxing authorities | |
| (401,891 | ) |
Total unrecognized tax benefit – December 31, 2023 | |
| 19,688,166 | |
Adjustment to prior year tax positions | |
| (26,739 | ) |
Increase for current year tax positions | |
| 2,183,671 | |
Settlements with taxing authorities | |
| (157,542 | ) |
Total unrecognized tax benefit –
December 31, 2024 | |
$ | 21,687,556 | |
|
Schedule of Material Jurisdictions |
The table below outlines the open tax years of the material jurisdictions.
Material
Jurisdictions | |
Open
Years |
United States | |
2021 - 2024 |
Singapore | |
2021 - 2024 |
Japan | |
2014 - 2024 |
Mainland China | |
2021 - 2024 |
Hong Kong | |
2017 - 2024 |
|