v3.25.4
Income Taxes
 12 Months Ended
Dec. 31, 2025
Income Taxes [Abstract]  
Income Taxes
20.
Income Taxes
(Loss) income
from continuing
operations before
income taxes
for the
years presented
below consisted
of the
following:
December 31,
(US$ thousands)
2025
2024
2023
U.S.
$
(31,293)
$
7,843
$
334,373
Non-U.S.
(413,122)
(157,033)
(210,559)
Total
$
(444,415)
$
(149,190)
$
123,814
Total
income tax benefit for the periods presented below consisted
of the following:
December 31,
(US$ thousands)
2025
2024
2023
Current:
U.S. federal
$
1,635
$
(867)
$
(6,303)
Non-U.S.
(166)
720
(2,715)
State
448
(636)
(1,895)
Total
current
1,917
(783)
(10,913)
Deferred:
U.S. federal
(12,156)
(61,977)
28,943
Non-U.S.
(551)
23,706
(45,976)
State
(1,569)
(1,255)
(4,305)
Total
deferred
(14,276)
(39,526)
(21,338)
Total
income tax benefit
$
(12,359)
$
(40,309)
$
(32,251)
As
further
described
in
Note
2,
Summary
of
Significant
Accounting
Policies,
the
Company
has
elected
to
prospectively
adopt
the
guidance
in
ASU
No.
2023-09,
Income
Taxes
(Topic
740):
Improvements
to
Income
Taxes
Disclosures, or
ASU 2023-09.
The following
table is
a reconciliation
of the
U.S. federal
statutory rate
of
21
% to the Company’s effective
rate for the year ended December
31, 2025 in accordance with
the guidance in
ASU No. 2023-09:
December 31,
(US$ thousands)
2025
U.S. federal statutory tax rate
$
(93,327)
21.0%
State and local income tax, net of federal (national) income
tax effect
(1)
(864)
0.2%
Foreign tax effects
Australia
Statutory tax rate difference between Australia and
United States
(37,070)
8.4%
Valuation allowance
109,438
(
24.6
%)
Foreign exchange permanent differences
14,992
(
3.4
%)
Other
(1,580)
0.4%
Effects of cross-border tax laws
U.S. impact of branch income at
3.4
%
(85,469)
19.2%
Changes in valuation allowance
81,640
(
18.4
%)
Non-taxable or non-deductible items
(1,765)
0.3%
Changes in unrecognized tax benefits
1,906
(
0.4
%)
Other adjustments
(260)
0.1%
Total
income tax benefit
$
(12,359)
2.8%
Effective tax rate
2.8%
(1)
State
taxes
in
West
Virginia
and
Virginia
made
up
the
majority
(greater
than
50%)
of
the
tax
effect
in
this
category.
The following is a
reconciliation of the
U.S. federal statutory
rate of
21
% to the Company’s
effective rate for
the
year ended December
31, 2024 and
2023, in accordance
with the guidance
prior to the adoption
of ASU 2023-
09:
December 31,
(US$ thousands)
2024
2023
Current:
Expected income tax expense at U.S. federal statutory rate
$
(31,330)
$
26,001
Percentage depletion
(3,407)
(17,871)
FDII deduction
—
(7,796)
Permanent differences
(1,130)
2,176
Prior period tax return adjustments and amendments
(1,347)
(46,060)
Uncertain tax positions
(1,007)
21,243
U.S. and residual tax on foreign earnings
(32,007)
(11,146)
Australian branch impact on US taxes
29,924
(3,406)
State income taxes, net of federal benefit
(5)
4,608
Total
income tax benefit
$
(40,309)
$
(32,251)
Effective tax rate
27%
(
26.0
%)
The
2023
prior
period
tax
return
adjustment
and
amendments
relates
predominantly
to
a
Foreign
Derived
Intangible Income
(“FDII”) deduction
in the
U.S. which
the Company
has chosen
to deduct
after undertaking
a
study to confirm the Company’s eligibility.
Deferred income taxes
reflect the net
tax effects of
temporary differences between the
carrying amounts of
assets
and liabilities
for financial
reporting purposes
and the
amount used
for income
tax purposes
using the
enacted
tax rates and laws currently
in effect. Significant components
of the Company’s deferred
income tax assets and
liabilities as of December 31, 2025 and 2024 were as follows:
December 31,
(US$ thousands)
2025
2024
Deferred income tax assets:
Accruals and provisions
$
54,488
$
40,594
Contract obligations
91,754
90,849
Lease obligations
47,327
43,633
Asset retirement obligation
56,845
59,981
Goodwill
6,510
6,047
Tax
losses
331,732
115,695
Interest limitation carried forward
74,788
26,943
Other
12,158
31,228
Gross deferred income tax assets
675,602
414,970
Valuation allowance
(1)
(316,489)
(114,088)
Total
deferred income tax assets, net of valuation allowance
359,113
300,882
Deferred income tax liabilities:
Property, plant, equipment
and mine development, principally due to
differences in depreciation, depletion and asset
impairments
(313,866)
(277,424)
Warehouse stock
(18,053)
(12,209)
Right of use asset
(44,085)
(41,947)
U.S. liability on foreign deferred taxes
—
—
Other
(6,358)
(6,039)
Total
deferred income tax liabilities
(382,362)
(337,619)
Net deferred income tax liability
$
(23,249)
$
(36,737)
(1)
As of
December 31,
2025, the
Company recorded a
valuation allowance
of $
316.5
million (2024:
$
114.1
million)
against deferred tax
assets consisting predominantly of
tax losses, land
and goodwill. A
valuation allowance must
be established for deferred
tax assets if it is “more
-likely-than-not” that they will
not be realized. The
increase in
the valuation
allowance of
$
202.4
million for
the year
was predominantly
driven by
tax losses
incurred in
2025
which have
not been
recognized.
Under Australian
tax law,
tax losses
may be
carried forward
indefinitely and
utilized
subject
to
meeting
the
tax
loss
recoupment
rules,
which
broadly
look
at
whether
the
Company
has
maintained the
same majority
ownership and
control, and
failing that,
whether the
Company has
maintained a
similar business.
In the
United
States,
tax
losses
may
be carried
forward
indefinitely
but
can
only
be
used
to
shelter 80% of future taxable income in any year
.
For U.S. tax purposes,
the group had tax
losses carried forward of
$
140.0
million at December
31, 2025 (2024:
$
26.9
million)
(tax
effected).
At
December
31,
2025,
the
Australian
tax
consolidated
group
had
tax
losses
of
$
179.3
million carried forward (2024: $
80.4
million) (tax effected). A company,
which is not part of the Australian
tax consolidated
group, had
tax losses
carried forward
of $
12.1
million at
December 31,
2025 (2024:
$
10.6
million)
(tax effected) for which an equal valuation has
been recognized.
BEPS Pillar Two:
Australian legislation enacted for global and minimum
domestic taxes
In December 2024, the Australian Government enacted legislation that implemented key aspects of Pillar Two of
the OECD/G20 Two-Pillar Solution which includes a 15% global minimum tax for large multinational
enterprises.
This legislation did not have any impact on
the Company in the current year and will
be monitored going forward.
On July
4, 2025,
the One
Big Beautiful
Bill Act
(the “Act”)
was signed
into law.
The legislation
include a
broad
range
of
tax
reform
provisions
affecting
businesses
including,
but
not
limited
to,
the
expansion
of
bonus
depreciation, immediate
expensing of domestic
R&D costs,
and revisions to
the U.S. taxation
of profits derived
from international operations. The
legislation has multiple
effective dates, with certain
provisions effective in fiscal
year
2025
and
others
implemented
through
fiscal
year
2027.
The
Act
did
not
have
a
material
impact
on
the
Company’s financial position and results of operations
as of and for the fiscal year ended December 31, 2025.
Unrecognized Tax
Benefits
The
Company
provides
for
uncertain
tax
positions,
and
the
related
interest
and
penalties,
based
upon
management’s assessment of whether a tax benefit is
more likely than not to be sustained upon examination by
tax authorities.
To the extent that the
anticipated tax outcome
of these uncertain
tax positions changes,
such changes in
estimate
will impact the income tax
provision in the period in which
such determination is made. The Company
recognizes
accrued interest and penalties related to uncertain tax
positions as a component of income tax expense.
The effect
of the total
amount of unrecognized
tax benefits,
if recognized, would
reduce our future
effective tax
rate.
December 31,
(US$ Thousands)
2025
2024
At beginning of the year
$
18,897
$
20,784
Additions based on tax positions related to current year
—
122
Additions for tax positions of prior years
992
2,342
Reductions for tax positions of prior year (including impacts
due to lapse
in statute)
(586)
(4,351)
At end of the year
19,303
18,897
The
return
to
provision
adjustments
for
2023
reflect
a
reduction
due
to
results
from
the
study
conducted
by
specialists and the
fact that the
benefit was limited
to taxable income.
For the year
ended December 31,
2025,
the Company recorded interest of $
1.5
million (2024: $
0.5
million).
The Company is subject to taxation in
the United States and Australia. As of December 31, 2025,
tax years 2021
to 2024 are open to review
from taxation authorities in the United States. In
Australia, tax years 2021 to 2024
are
open to review.
In 2025,
material jurisdictions
that are
equal or
greater than
5% of
the total
cash refund
for taxes
as disclosed
including
state
taxes
in
West
Virginia
($
1.5
million).
No
federal
or
foreign
taxes
were
paid
or
received
during
2025.