NOTE 20 – INCOME TAXES

 

Provision for Income Taxes

 

The components of the provision for income taxes were as follows:

 

 

 

2025

 

 

2024

 

Current Taxes

 

 

 

 

 

 

U.S. Federal

 

 

(148,300)

 

 

148,300

 

Foreign

 

 

2,245,978

 

 

 

3,196,802

 

Current Taxes

 

 

2,097,678

 

 

 

3,345,102

 

 

 

 

 

 

 

 

 

 

Deferred Taxes

 

 

 

 

 

 

 

 

U.S. Federal

 

 

(1,303,296)

 

 

197,295

 

Foreign

 

 

(6,000,576)

 

 

(924,030)

Deferred Taxes

 

 

(7,303,872)

 

 

(726,735)

 

 

 

 

 

 

 

 

 

Provision for income taxes

 

 

(5,206,194)

 

 

2,618,367

 

 

U.S. and foreign components of income before taxes were as follows:

 

2025

 

 

2024

 

United States

 

 

(36,126,857)

 

 

(9,022,353)

Foreign

 

 

(61,061,473)

 

 

11,030,871

 

Income before income taxes

 

 

(97,188,330)

 

 

1,208,518

 

 

Effective Tax Rate

 

The following table reconciles the U.S. statutory tax rate to our effective income tax rate for the year ended December 31, 2025, as required by ASU 2023-09 (see " Recently adopted accounting pronouncements" caption in for more information):

 

 

 

For the Year Ended December 31,

 

 

 

2025

 

U.S. Federal statutory income tax rate

 

 

(20,409,549)

 

 

21.0%

Foreign tax effects

 

 

 

 

 

 

 

 

Australia

 

 

 

 

 

 

 

 

Goodwill Impairment

 

 

2,264,349

 

 

 

-2.3%

Other

 

 

(655,746)

 

 

0.7%

United Kingdom

 

 

 

 

 

 

 

 

Goodwill Impairment

 

 

9,413,835

 

 

 

-9.7%

Foreign Rate Differential

 

 

(2,213,700)

 

 

2.3%

Other

 

 

2,039,610

 

 

 

-2.1%

Other foreign jurisdictions

 

 

(1,780,037)

 

 

1.8%

Effect of cross-border laws

 

 

 

 

 

 

 

 

GILTI Inclusion

 

 

2,031,562

 

 

 

-2.1%

Sec. 250 Deduction

 

 

(496,847)

 

 

0.5%

Other

 

 

1,829

 

 

 

0.0%

Non-taxable or non-deductible items

 

 

 

 

 

 

 

 

Goodwill Impairment

 

 

3,735,779

 

 

 

-3.8%

Other

 

 

862,721

 

 

 

-0.9%

Effective Income Tax Expense

 

 

(5,206,194)

 

 

5.4%

 

A reconciliation of the provision for income taxes to the amount computed by applying the 21% statutory U.S. federal income tax rate to income before income taxes for years prior to the adoption of ASU 2023-09 is as follows:

 

 

 

For the Year Ended December 31,

 

 

 

2024

 

Income tax expense at federal statutory rate

 

 

253,789

 

Stock-based Compensation

 

 

971,787

 

Transaction Costs

 

 

202,069

 

GILTI Inclusion

 

 

1,234,434

 

Representation Expenses

 

 

23,302

 

Impairment of Assets

 

 

6,750

 

Effects of Transfer Pricing

 

 

64,601

 

Other Permanent Items

 

 

4,646

 

Tax Credits

 

 

(1,488,973)

Foreign Rate Differential

 

 

(948,027)

Other Taxes

 

 

825,519

 

Tax Contingency

 

 

1,468,472

 

Income Tax Expense

 

 

2,618,369

 

 

Cash Taxes Paid

 

The components of cash income taxes paid net of refunds are as follows:

 

 

 

For the Year Ended December 31,

 

 

 

2025

 

Income taxes paid

 

 

 

Federal

 

 

-

 

Foreign

 

 

 

 

Australia

 

 

495,728

 

Bosnia

 

 

236,674

 

Montenegro

 

 

342,102

 

Peru

 

 

274,517

 

Serbia

 

 

346,699

 

United Kingdom

 

 

346,139

 

Other

 

 

30,080

 

 

 

 

 

 

Total

 

 

2,071,939

 

 

Deferred Taxes

 

Deferred income taxes reflect the net tax effects of temporary differences between the bases of assets and liabilities for financial reporting and income tax purposes. The Company's deferred tax assets and liabilities consisted of the following:

 

 

 

2025

 

 

2024

 

Deferred Tax Assets:

 

 

 

 

 

 

Net operating loss

 

 

2,915,964

 

 

 

277,950

 

Employee Benefits

 

 

94,828

 

 

 

2,341

 

Other

 

 

291,438

 

 

 

106,619

 

Gross Deferred Tax Assets

 

 

3,302,230

 

 

 

386,910

 

Valuation Allowance

 

 

(2,731,965)

 

 

-

 

Total Deferred Tax Assets

 

 

570,265

 

 

 

386,910

 

 

 

 

 

 

 

 

 

 

Deferred Tax Liabilities

 

 

 

 

 

 

 

 

Depreciation and Amortization

 

 

0

 

 

 

6,980,141

 

Other

 

 

76,602

 

 

 

14,124

 

Total Deferred Tax Liabilities

 

 

76,602

 

 

 

6,994,265

 

 

 

 

 

 

 

 

 

 

Net deferred tax liability

 

 

493,662

 

 

 

(6,607,355)

 

The Company assesses the available positive and negative evidence to estimate if sufficient future taxable income will be generated to use the existing deferred tax assets. The valuation allowance disclosed in the table above relates to the foreign net operating loss carryforwards that may not be realized. The Company will continue to evaluate the need to adjust the valuation allowance. The amount of the deferred tax asset considered realizable, however, could be adjusted depending on the Company's performance in certain subsidiaries or jurisdictions.

 

Deferred taxes consist of net deferred tax assets of $0.5 million, inclusive of a valuation allowance of $2.7 million as of December 31, 2025. Our valuation allowance increased by $2.7 million for the year ended December 31, 2025, respectively, due primarily to foreign net operating losses. The Company does not anticipate any significant changes to the total amount of unrecognized deferred tax assets within the next 12 months following the reporting date. Deferred tax assets have not been recognized with respect to these items because it is not probably that future taxable profit will be available against which the Company can utilize the benefits.

 

As of December 31, 2025, the Company has gross foreign net operating loss carryforwards of $10.2 million. These net operating losses are eligible to be carried forward indefinitely. Recognition of some of these loss carryforwards is subject to an annual limit.

 

At December 31, 2025, the Company had no unrecognized tax benefits and does not anticipate any unrecognized tax benefits. Should the recognition of any interest or penalties relative to unrecognized tax benefits be necessary, it is the Company’s policy to record such expenses in the Company’s income tax accounts. No such accruals existed at December 31, 2025.

 

The Company is subject to examination in the United States, Serbia, and other foreign jurisdictions. As of December 31, 2025, tax years 2019 to 2025 are subject to examination by the tax authorities.

Historical Timeline

Fiscal YearFiled
2025Mar 31, 2026Showing above
2024Mar 24, 2025
2023Jan 17, 2024
2022Jan 30, 2023
2021Apr 30, 2021

About Income Taxes Disclosures

The income tax disclosure reveals how much a company actually pays in taxes versus what the statutory rate would predict. Analysts focus on the effective tax rate (ETR) reconciliation, which breaks down every item driving the gap between the 21% federal rate and the company's reported ETR — including R&D credits, foreign rate differentials, and state taxes. Deferred tax assets (DTAs) and their valuation allowances signal management's confidence in future profitability: a rising allowance suggests the company doubts it can use accumulated tax benefits. Uncertain tax benefit (UTB) reserves quantify exposure to IRS challenges on aggressive positions.

Key signals to watch: sudden ETR drops without clear operational reasons, large increases in valuation allowances, growing UTB balances, and significant unremitted foreign earnings. Post-TCJA, pay attention to GILTI and BEAT provisions that affect multinational tax structures. Compare the cash taxes paid (from the cash flow statement) against the income tax provision to gauge earnings quality.