v3.26.1
Income Taxes
12 Months Ended
Dec. 31, 2025
Income Taxes [Abstract]  
INCOME TAXES

13. INCOME TAXES

 

Income (loss) before income taxes is attributable to the following geographic locations for the years ended December 31:

 

   For the Years Ended
December 31,
 
   2025   2024 
Domestic (loss) income before income taxes $(11,205,757) $(839,368)
Foreign (loss) income before income taxes (14,562,613) 3,083,387 
Total (loss) income before income taxes $(25,768,370) $2,244,019 

  

The tax expense (benefit) for income taxes consisted of the following components for the years ended December 31:

 

   For the Years Ended
December 31,
 
   2025   2024 
Current:        
Federal $657,249  $247,244 
State  -   - 
Foreign  (1,030,416)  861,943 
Total current income taxes  (373,167) $1,109,187 
Deferred:          
Federal  (2,431,059)  (15,395)
State  (147,977)  - 
Foreign  1,866,371  (219,615)
Total deferred income taxes  (712,665)  (235,010)
Total income tax (benefit)/provision $(1,085,832) $874,177 

 

Taxes not based on income are not treated as income tax expense, and excluded from provision for income taxes and the aggregate amounts were not significant for the years ended December 31, 2025 and 2024.

 

We applied ASU 2023-09 on a prospective basis as discussed in Note 2. Summary of Significant Accounting Policies. Accordingly, the disaggregation of rate reconciliation categories in the table below provide the disclosures require by ASU 2023-09 for the year ended December 31, 2025.

 

The reconciliation of the U.S. federal statutory income tax rate to the 2025 effective income tax rate was as follows:

 

   For the Year Ended
December 31, 2025
 
   Amount $   Percentage % 
Federal tax at statutory rate $(5,411,357)  21.0%
Domestic federal          
Nontaxable or nondeductible items  (77,849)  0.3%
Cross-border tax laws          
GILTI inclusions  

657,500

   (2.6)%
Other reconciling items  (251)  0.0%
Domestic state income taxes, net of federal effect (1)  (147,976)  0.6%
           
Foreign tax effects          
Canada          
Stock based compensation  965,575   (3.7)%
Other  (360,970)  1.4%
Statutory income tax rate differential  660,095   (2.6)%
           
Cayman Islands          
Statutory income tax rate differential  2,735,717   (10.6)%
           
Other foreign jurisdictions  (106,316)  0.4%
           
Worldwide changes in unrecognized tax benefits  -   0.0%
           
Total income tax expense $(1,085,832) $4.2%

  

(1)State taxes in Nebraska, Pennsylvania contributed to the majority of the tax effect in this category.

Income tax expense(benefit) for the year ended December 31, 2024 differed from the amounts computed by applying the U.S. federal income rate of 21% to pre-tax income as a result of the following:

 

   Year Ended
December 31,
 
   2024 
US Federal income tax rate  21.0%
Effect of foreign operations taxed at various rates  -0.3%
GILTI Inclusion  18.2%
Non-deductible Fixed Asset Impairment  1.1%
Effect of change in valuation allowance  (1.0)%
Others  0.0%
Effective income tax rate  39.0%

 

Our accounting policy is to treat any tax on Global Intangible Low-Taxed Income or GILTI inclusions as a current period cost included in the tax expense in the year incurred. We estimate the GILTI inclusion provision will result in no material financial statement impact.

 

The significant components of deferred income tax assets and liabilities were as follows:

 

   December 31,
2025
   December 31,
2024
 
Deferred tax assets:        
Net operating losses carry forwards $

9,052,613

  $1,318,934 
Share-based compensation  690,364   645,786 
Lease liabilities  1,269,745   2,085,460 
Unrealized foreign exchange gain/loss  -   277 
Foreign lease  

800,677

   - 
Start-up cost amortization  73,344   - 
Accrued Expenses  180,795   - 
Other deferred tax assets  50,471   92,816 
Gross deferred tax assets  12,118,009   4,143,273 
Less: valuation allowance  (84,595)  - 
Net deferred tax assets $12,033,414  $4,143,273 
           
Deferred tax liabilities:          

Right-of-use asset

 $(1,673,657) $(2,479,301)
Basis difference in fixed assets  (7,114,767)  (1,932,206)
Allowance for bad debt  (239,891)  - 
Unrealized foreign exchange gain/loss  (24,960)  - 
Prepaid assets  (55,036)  - 
Capitalized contract costs  (2,753,633)  - 
CTA  (101,851)  - 
Basis difference in intangible  (3,174,107)  (3,403,248)
Gross deferred tax liabilities  (15,137,902)  (7,814,755)
Total net deferred tax liabilities $(3,104,488) $(3,671,482)

 

Our accounting for deferred taxes requires an assessment of the realizability of deferred tax assets in each taxing jurisdiction, based on the weight of available positive and negative evidence. In evaluating the need for a valuation allowance, we considered factors among duration of current and cumulative financial reporting losses, future reversals of existing taxable temporary differences, future taxable income exclusive of reversing temporary differences and carryforwards, taxable income in carryback years if carryback is permitted by the tax law, and feasible tax-planning strategies.

 

Based on this analysis, we concluded that valuation allowances were required in certain jurisdictions. In particular, the operations in the jurisdictions for which a valuation allowance has been recorded have experienced a history of losses as of December 31, 2025. Accordingly, we do not believe that these operations have established sustained profitability sufficient to support the realization of their deferred tax assets. As a result, a valuation allowance has been recorded to reduce the deferred tax assets to the amounts that are more likely than not to be realized.

 

Changes in the valuation allowance for deferred tax assets for the years ended December 31 are as follows:

 

   For the Years Ended
December 31,
 
   2025   2024 
         
Beginning balance $-  $     - 
Current increase  84,595   - 
Ending Balance $84,595   - 

 

Our net operating loss carryforwards for federal, state and foreign tax purposes which expire, if not utilized, at various intervals from 2026, are outlined below:

 

Expiration Date(1) (2)  Federal   State   Foreign 
2026  -   -   - 
2027 to 2030  -   -   - 
2031 to 2035  -   -   1,074,393 
2036 to 2040  -   14,403,560   - 
2041 to 2045  -   1,621,761   11,987,133 
2046 to 2050  -   -   - 
2051 to 2055  -   -   - 
Indefinite  25,246,110   361,210   - 
   25,246,110   16,386,531   13,061,526 

 

(1) In certain jurisdictions, the net operating loss carryforwards can only be used to offset a percentage of taxable income in a given year.
   
(2) The amounts are gross.

 

The Company has no unrecognized tax benefits as of December 31,2025 and 2024 respectively.

 

In the ordinary course of business, the Company is subject to examination by tax authorities in various jurisdictions. With respect to U.S. federal and state income taxes, tax years beginning on or after December 31, 2024 remain open to examination. For foreign jurisdictions in which the Company operates, tax years beginning on or after December 31, 2023 remain open to examination through the current year, subject to applicable statutes of limitations. As of the December 31, 2025, the Company is not under audit by any taxing authority in the jurisdictions in which it operates.

 

We applied ASU 2023-09 on a prospective basis as discussed in Note 2. Summary of Significant Accounting Policies. Accordingly, the income taxes paid/(refund) by jurisdiction (net of refunds received) below provide the disclosures required by ASU 2023-09 for the year ended December 31, 2025:

 

   2025 
US federal $225,000 
US states  - 
Foreign     
Iceland  373,182 
Total foreign  373,182 
Total income taxes paid (net of refund received) $598,182 

 

On July 4, 2025, President Trump signed into law the reconciliation bill, commonly referred to as the One Big Beautiful Bill Act (“OBBBA”). The OBBBA introduces several changes to U.S. federal income tax law, such as suspending the capitalization and amortization of domestic research and development expenditures and reinstating bonus depreciation. It also modifies the deductions available for net controlled foreign corporation tested income (formerly referred to as “global intangible low-taxed income”) from non-U.S. subsidiaries and changes the limitations on deductible interest. The effective dates of the OBBBA provisions range from 2025 through 2027. We do not expect the OBBBA provisions to have a material impact on our consolidated financial statements.