INCOME AND MINING TAXES
The Company’s Income and mining tax benefit (expense) consisted of:
| | | | | | | | | | | | | | | | | |
| Year Ended December 31, |
| 2025 | | 2024 | | 2023 |
| Current: | | | | | |
| United States | $ | (157) | | | $ | (93) | | | $ | (20) | |
| Foreign | (3,048) | | | (1,224) | | | (610) | |
| (3,205) | | | (1,317) | | | (630) | |
| Deferred: | | | | | |
| United States | (96) | | | (157) | | | 62 | |
| Foreign | (1,295) | | | 77 | | | 42 | |
| (1,391) | | | (80) | | | 104 | |
| Income and mining tax benefit (expense) | $ | (4,596) | | | $ | (1,397) | | | $ | (526) | |
The Company’s Income (loss) before income and mining tax and other items is attributable to the following jurisdictions:
| | | | | | | | | | | | | | | | | |
| Year Ended December 31, |
| 2025 | | 2024 | | 2023 |
| United States | $ | 1,527 | | | $ | 536 | | | $ | 111 | |
| Foreign | 9,815 | | | 4,041 | | | (2,142) | |
| Income (loss) before income and mining tax and other items | $ | 11,342 | | | $ | 4,577 | | | $ | (2,031) | |
The Company’s Income and mining tax benefit (expense) differed from the amounts computed by applying the United States statutory corporate income tax rate for the following reasons:
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| Year Ended December 31, (1) |
| 2025 | | 2024 | | 2023 |
| Income (loss) before income and mining tax and other items | | | $ | 11,342 | | | | | $ | 4,577 | | | | | $ | (2,031) | |
| | | | | | | | | | | |
| U.S. Federal statutory tax rate | 21 | % | | $ | (2,382) | | | 21 | % | | $ | (961) | | | 21 | % | | $ | 427 | |
| | | | | | | | | | | |
| Reconciling items: | | | | | | | | | | | |
Domestic state and local income taxes, net of federal income tax effect (2) | 1 | % | | (78) | | | 1 | % | | (35) | | | (1) | % | | (25) | |
| Domestic federal: | | | | | | | | | | | |
| Tax Credits | — | % | | — | | | (1) | % | | 37 | | | 1 | % | | 19 | |
| Nontaxable and nondeductible items: | | | | | | | | | | | |
| Percentage depletion | (1) | % | | 83 | | | (1) | % | | 63 | | | 4 | % | | 72 | |
| Other nontaxable and nondeductible items | 1 | % | | (76) | | | — | % | | (3) | | | (1) | % | | (14) | |
| Cross-border tax laws | — | % | | (17) | | | — | % | | (21) | | | — | % | | (10) | |
| Changes in valuation allowance | — | % | | 18 | | | (1) | % | | 34 | | | 9 | % | | 192 | |
Impact of Transactions | (2) | % | | 278 | | | 3 | % | | (157) | | | — | % | | — | |
| Impact of Foreign Tax Credit and U.S. Capital Losses Expiration | — | % | | — | | | — | % | | — | | | (10) | % | | (195) | |
| Other | — | % | | 9 | | | 1 | % | | (53) | | | — | % | | — | |
| Worldwide changes in unrecognized tax benefits | — | % | | (1) | | | (1) | % | | 63 | | | 1 | % | | 28 | |
| Foreign tax effects: | | | | | | | | | | | |
| Argentina: | | | | | | | | | | | |
| Tax impact of foreign exchange | (1) | % | | 65 | | | 2 | % | | (93) | | | 2 | % | | 34 | |
| Changes in valuation allowance | — | % | | (28) | | | (2) | % | | 94 | | | (3) | % | | (56) | |
| Other | — | % | | (15) | | | 1 | % | | (36) | | | — | % | | 7 | |
| Australia: | | | | | | | | | | | |
| Northern Territory Mineral Royalty | 1 | % | | (127) | | | 2 | % | | (79) | | | (3) | % | | (62) | |
| Changes in valuation allowance | (1) | % | | 60 | | | 1 | % | | (24) | | | 1 | % | | 30 | |
| Other | — | % | | (19) | | | (1) | % | | 30 | | | — | % | | (4) | |
| Rate differential for foreign earnings indefinitely reinvested | 4 | % | | (304) | | | 3 | % | | (157) | | | (10) | % | | (195) | |
| Canada: | | | | | | | | | | | |
| Mining and other taxes (net of associated federal benefit) | — | % | | (46) | | | 2 | % | | (92) | | | — | % | | (2) | |
| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |
| Tax impact of foreign exchange | — | % | | (25) | | | (2) | % | | 73 | | | (2) | % | | (36) | |
| Rate differential for foreign earnings indefinitely reinvested | — | % | | (51) | | | — | % | | 9 | | | 1 | % | | 27 | |
| Changes in valuation allowance | 1 | % | | (69) | | | (4) | % | | 182 | | | (1) | % | | (26) | |
| Goodwill impairment | — | % | | — | | | — | % | | — | | | (7) | % | | (135) | |
| Other | 1 | % | | (91) | | | (1) | % | | 39 | | | — | % | | — | |
Ghana: (3) | | | | | | | | | | | |
| Rate differential for foreign earnings indefinitely reinvested | 1 | % | | (158) | | | 3 | % | | (115) | | | (3) | % | | (55) | |
| Transactions | 1 | % | | (168) | | | — | % | | — | | | — | % | | — | |
| Permanent Assertion Removal | 1 | % | | (165) | | | — | % | | — | | | — | % | | — | |
| Other | 1 | % | | (74) | | | 1 | % | | (27) | | | (1) | % | | (11) | |
| Mexico: | | | | | | | | | | | |
| Tax impact of foreign exchange | — | % | | 52 | | | (1) | % | | 57 | | | — | % | | (1) | |
| Mining Tax | 1 | % | | (126) | | | — | % | | (12) | | | — | % | | 8 | |
| Rate differential for foreign earnings indefinitely reinvested | 1 | % | | (135) | | | 1 | % | | (54) | | | 8 | % | | 162 | |
| Changes in valuation allowance | 1 | % | | (57) | | | — | % | | 18 | | | (2) | % | | (34) | |
| Goodwill impairment | — | % | | — | | | — | % | | — | | | (18) | % | | (363) | |
| Prior period adjustment | — | % | | — | | | — | % | | — | | | (1) | % | | (27) | |
| Other | — | % | | (10) | | | 1 | % | | (37) | | | 1 | % | | (11) | |
| PNG: | | | | | | | | | | | |
| Permanent Assertion Removal | 4 | % | | (384) | | | — | % | | — | | | — | % | | — | |
| Other | 1 | % | | (134) | | | 1 | % | | (48) | | | — | % | | (8) | |
| Peru: | | | | | | | | | | | |
| Rate differential for foreign earnings indefinitely reinvested | — | % | | (40) | | | 1 | % | | (30) | | | 4 | % | | 91 | |
| Changes in valuation allowance | 2 | % | | (282) | | | — | % | | 13 | | | (16) | % | | (329) | |
| Other | 1 | % | | (64) | | | 1 | % | | (37) | | | — | % | | (4) | |
| | | | | | | | | | | |
| | | | | | | | | | | |
| Other foreign jurisdictions: | | | | | | | | | | | |
| Rate differential for foreign earnings indefinitely reinvested | — | % | | — | | | — | % | | 1 | | | — | % | | 2 | |
| Other | — | % | | (35) | | | — | % | | (39) | | | — | % | | (22) | |
| Income and mining tax benefit (expense) | 40 | % | | $ | (4,596) | | | 31 | % | | $ | (1,397) | | | (26) | % | | $ | (526) | |
____________________________(1)Percentages presented may not recalculate due to rounding.
(2)State taxes are comprised entirely of Nevada Net Proceeds Tax, net of federal benefit.
(3)Pursuant to the expiration of the Financial and Tax Stability Periods established by the Revised Investment Agreement in Ghana on December 31, 2025, the statutory tax rate for the Ahafo operations increased to 35% from 32.5%. The deferred balances were adjusted for the change to the tax rate and a $20 tax expense was recorded.
Factors that Significantly Impact Effective Tax Rate (Other than Factors Described Separately Below)
Percentage depletion allowances (tax deductions for depletion that may exceed the tax basis in the mineral reserves) are available to the Company under the income tax laws of the United States for operations conducted in the United States or through branches and partnerships owned by U.S. subsidiaries included in the consolidated United States income tax return. These deductions are highly sensitive to the price of gold and other metals produced by the Company.
The Company operates in various jurisdictions around the world that have statutory tax rates that are significantly different than those of the U.S. These differences combine to move the overall effective tax rate higher than the U.S. statutory rate.
Mining taxes in Nevada, Mexico, Canada, Peru, and Australia represent state and provincial taxes levied on mining operations and are classified as income taxes as such taxes are based on a percentage of mining profits.
In the U.S., capital losses may be carried forward five years to offset capital gains. Capital loss carryforwards of $—, $222, and $—, expired in 2025, 2024 and 2023, respectively. The Company carries a full valuation allowance on U.S. capital losses.
In 2025, 2024, and 2023, the U.S. had foreign tax credits of $—, $—, and $193, respectively, expire.
Components of the Company's deferred income tax assets (liabilities) are as follows:
| | | | | | | | | | | |
| At December 31, |
| 2025 | | 2024 |
| Deferred income tax assets: | | | |
| Property, plant and mine development | $ | 1,257 | | | $ | 887 | |
| Inventory | 100 | | | 132 | |
| Reclamation and remediation | 2,246 | | | 2,077 | |
| Net operating losses, capital losses and tax credits | 2,217 | | | 2,297 | |
| | | |
| Employee-related benefits | 50 | | | 24 | |
| Derivative instruments and unrealized loss on investments | 10 | | | 79 | |
| Foreign exchange and financing obligations | 90 | | | 58 | |
| Silver streaming agreement | 203 | | | 253 | |
| Other | 546 | | | 555 | |
| 6,719 | | | 6,362 | |
| Valuation allowances | (4,782) | | | (4,363) | |
| 1,937 | | | 1,999 | |
| Deferred income tax liabilities: | | | |
| Property, plant and mine development | (4,320) | | | (3,749) | |
| Inventory | (228) | | | (132) | |
| Investment in partnerships and subsidiaries | (1,192) | | | (582) | |
| Other | (197) | | | (232) | |
| (5,937) | | | (4,695) | |
| Net deferred income tax assets (liabilities) | $ | (4,000) | | | $ | (2,696) | |
These amounts reflect the classification and presentation that is reported for each tax jurisdiction in which the Company operates.
Valuation of Deferred Tax Assets
The Company assesses the available positive and negative evidence to estimate if sufficient future taxable income will be generated to utilize the existing deferred tax assets. A significant piece of objective negative evidence evaluated was the recent pretax losses and/or expectations of future pretax losses. Such objective evidence limits the ability to consider other subjective evidence such as the Company's projections for future growth. However, the amount of the deferred tax asset considered realizable could be adjusted if estimates of future taxable income during the carryforward period are increased, if objective negative evidence in the form of cumulative losses is no longer present or if additional weight were given to subjective evidence such as the Company's projections for growth.
During 2025, the Company recorded an increase to the valuation allowance of $295 and a corresponding tax expense, primarily driven by increases in the net deferred tax assets in Argentina and Peru, the valuation allowance on Canada's capital loss, offset by the release associated with the utilization of capital loss carryforwards in the U.S. and Australia.
Refer to Note 2 for additional risk factors that could impact the Company’s ability to realize the deferred tax assets.
Tax Loss Carryforwards, Foreign Tax Credits, and Canadian Tax Credits
At December 31, 2025 and 2024, the Company had (i) $1,524 and $2,005 of net operating loss carry forwards, respectively; and (ii) $563 and $414 of tax credit carry forwards, respectively. At December 31, 2025 and 2024, $429 and $760, respectively, of net operating loss carry forwards are attributable to the U.S., Australia, and France for which current tax law provides no expiration period. The net operating loss carry forward in Canada of $577 will expire by 2044. The net operating loss carryforward in Mexico of $187 will expire by 2034. The net operating loss carry forward in other countries is $331.
The U.S. tax credit carry forwards for 2025 and 2024, were $369 and $337, respectively. The foreign tax credits will substantially all expire at the end of 2035, and the solar tax credit for 2024 of $28 will expire by 2046. Canadian tax credits for 2025 and 2024 of $194 and $77, respectively, consist of investment tax credits and minimum mining tax credits. Canadian investment tax credits for 2025 consisted of $93 which will substantially expire by 2044.
Income and Mining Taxes Paid, Net of Refunds
The amounts of income and mining taxes paid, net of refunds, by the Company are as follows:
| | | | | | | | | | | | | | | | | |
| Year Ended December 31, |
| 2025 | | 2024 | | 2023 |
| U.S. Federal | $ | 17 | | | $ | 1 | | | $ | (1) | |
| U.S. State and local: | | | | | |
| Nevada | 50 | | | 40 | | | 19 | |
| Foreign: | | | | | |
| Australia | 737 | | | 341 | | | 414 | |
| Canada | * | | 64 | | | * |
| Ghana | 675 | | | 418 | | | 223 | |
| Mexico | 315 | | | * | | 93 | |
PNG | 158 | | | * | | * |
Peru | 341 | | | * | | * |
| Other | 165 | | | 102 | | | 46 | |
| Total income and mining taxes paid, net of refunds | $ | 2,458 | | | $ | 966 | | | $ | 794 | |
____________________________*The amount of income and mining taxes paid, net of refunds during the year does not meet the 5% disaggregation threshold.
Company’s Unrecognized Tax Benefits
A reconciliation of the beginning and ending amount of gross unrecognized tax benefits, exclusive of interest and penalties, is as follows:
| | | | | | | | | | | | | | | | | |
| 2025 | | 2024 | | 2023 |
| Total amount of gross unrecognized tax benefits at beginning of year | $ | 111 | | | $ | 144 | | | $ | 190 | |
| Additions (reductions) for tax positions of prior years | 10 | | | (8) | | | 13 | |
| Additions for tax positions of current year | — | | | — | | | 2 | |
| Reductions due to settlements with taxing authorities | (12) | | | (2) | | | (18) | |
| Reductions due to lapse of statute of limitations | (5) | | | (23) | | | (43) | |
| Total amount of gross unrecognized tax benefits at end of year | $ | 104 | | | $ | 111 | | | $ | 144 | |
At December 31, 2025, 2024, and 2023, $128, $125, and $190, respectively, represent the amount of unrecognized tax benefits, inclusive of interest and penalties that, if recognized, would impact the Company’s effective income tax rate.
The Company operates in numerous countries around the world and is subject to, and pays annual income taxes under, the various income tax regimes in the countries in which it operates. Some of these tax regimes are defined by contractual agreements with the local government, and others are defined by the general corporate income tax laws of the country. The Company has historically filed, and continues to file, all required income tax returns and paid the taxes reasonably determined to be due. The tax rules and regulations in many countries are highly complex and subject to interpretation. From time to time, the Company is subject to a review of its historic income tax filings and in connection with such reviews, disputes can arise with the taxing authorities over the interpretation or application of certain rules to the Company’s business conducted within the country involved.
The Company and/or subsidiaries file income tax returns in the U.S. Federal jurisdiction, and various state and foreign jurisdictions. With few exceptions, the Company is no longer subject to U.S. Federal, state and local, and non-U.S. income tax examinations by tax authorities for years before 2016.
The Company’s practice is to recognize interest and/or penalties related to unrecognized tax benefits as part of Income and mining tax benefit (expense). At December 31, 2025 and 2024, the total amount of accrued income-tax-related interest and penalties included in the Consolidated Balance Sheets was $55 and $47, respectively. During 2025, 2024, and 2023 the Company increased $8 and $31, and released $1 of interest and penalties, respectively, through the Consolidated Statements of Operations.
Refer to Note 24 for further discussion of tax matters.
Other
In the fourth quarter of 2025, the Company has provided additional income taxes for the remaining undistributed foreign earnings in Ghana and Papua New Guinea, $165 and $384, respectively, as it was determined excess cash flow could not be remitted on a tax free basis for the foreseeable future. No additional income taxes have been provided in other jurisdictions for any additional outside basis difference inherent at these entities, as these amounts continue to be indefinitely reinvested in foreign operations.