| INCOME TAXES |
Effective January 1, 2025, the Company
adopted ASU 2023-09 on a prospective basis, which enhances the transparency and decision usefulness of income tax disclosures in our
financial statements. This update requires entities to disclose a detailed reconciliation of the federal statutory income tax rate to
the effective tax rate and the disaggregation of income (loss) before income taxes, income tax benefit (expense) and income taxes paid,
net of refunds by domestic federal, domestic state, and foreign jurisdictions. Furthermore, changes in unrecognized tax benefits must
be categorized based on their relation to current or prior annual reporting periods.
For financial reporting purposes, (loss) income
before income taxes includes the following components:
| | |
Year Ended December 31, | |
| | |
2025 | | |
2024 | | |
2023 | |
| United States | |
| (36,172 | ) | |
| (11,285 | ) | |
| (4,720 | ) |
| Foreign | |
| 6,908 | | |
| 72,916 | | |
| 17,398 | |
| Total (loss)/income before income taxes | |
| (29,264 | ) | |
| 61,631 | | |
| 12,678 | |
The components of the provision for income taxes
are as follows:
| | |
Year Ended December 31, | |
| | |
2025 | | |
2024 | | |
2023 | |
| | |
| | |
| | |
| |
| Current income tax expense/(benefit): | |
| | |
| | |
| |
| US-Federal | |
| - | | |
| - | | |
| - | |
| US-State | |
| 6 | | |
| - | | |
| - | |
| Foreign | |
| 938 | | |
| 877 | | |
| (1,968 | ) |
| Total current income tax expense/(benefit) | |
| 944 | | |
| 877 | | |
| (1,968 | ) |
| Deferred tax expense/(benefit): | |
| | | |
| | | |
| | |
| US-Federal | |
| (7,481 | ) | |
| (2,370 | ) | |
| (991 | ) |
| US-State | |
| (1,781 | ) | |
| (564 | ) | |
| (236 | ) |
| Foreign | |
| 933 | | |
| 9,725 | | |
| 5,378 | |
| Total deferred tax expense/(benefit) | |
| (8,329 | ) | |
| 6,791 | | |
| 4,151 | |
| Change in valuation allowance | |
| 9,263 | | |
| - | | |
| - | |
| Net deferred tax expense after valuation allowance | |
| 934 | | |
| 6,791 | | |
| 4,151 | |
| | |
| | | |
| | | |
| | |
| Total income tax expense | |
| 1,878 | | |
| 7,668 | | |
| 2,183 | |
| | |
| | | |
| | | |
| | |
| Effective tax rate | |
| (6.4 | )% | |
| 12.4 | % | |
| 17.2 | % |
The reconciliation of the U.S. federal
statutory income tax rate to the Company’s effective tax rate for the year ended December 31, 2025 was as follows:
| | |
For the Year Ended December 31,
2025 | |
| | |
| | |
| |
| Federal income tax benefit at the statutory rate | |
| (6,145 | ) | |
| 21.0 | % |
| Domestic Federal: | |
| | | |
| | |
| Change in valuation allowances | |
| 7,481 | | |
| (25.6) | % |
| Other adjustments | |
| 107 | | |
| (0.4) | % |
| Foreign Tax Effects: | |
| | | |
| | |
| Statuary income tax rate difference | |
| | | |
| | |
| Singapore | |
| 214 | | |
| (0.7) | % |
| UAE | |
| (3,935 | ) | |
| 13.4 | % |
| Hong Kong | |
| 427 | | |
| (1.4) | % |
| Cayman Island | |
| 2,179 | | |
| (7.4) | % |
| Others, net | |
| 1,550 | | |
| (5.3) | % |
| Income tax expense/(benefit) | |
| 1,878 | | |
| (6.4 | )% |
The Company adopted the updated guidance
for the year ended December 31, 2025, and applied the new disclosure requirements prospectively to the current annual period. Prior period
disclosures have not been adjusted to reflect the new disclosure requirements.
| | |
Year Ended December 31, | |
| | |
2024 | | |
2023 | |
| | |
| | |
| |
| Federal income tax benefit at the statutory rate | |
| (2,370 | ) | |
| (991 | ) |
| Effect of: | |
| | | |
| | |
| State income taxes | |
| (564 | ) | |
| (236 | ) |
| Foreign taxes | |
| 10,602 | | |
| 3,494 | |
| Other, net | |
| - | | |
| (84 | ) |
| Income tax expense/(benefit) | |
| 7,668 | | |
| 2,183 | |
The Company’s net deferred tax
assets/(liabilities) were as follows:
| | |
As of December 31, | |
| | |
2025 | | |
2024 | |
| | |
| | |
| |
| Deferred tax assets: | |
| | |
| |
| Impairment loss on mining equipment | |
| 10,747 | | |
| 5,181 | |
| Net operating loss carryforwards | |
| 6,610 | | |
| 7,742 | |
| Credit loss provision for receivables | |
| 10 | | |
| 81 | |
| Limits on interest expense deduction | |
| 5,194 | | |
| 3,683 | |
| Total gross deferred tax assets | |
| 22,561 | | |
| 16,687 | |
| | |
| | | |
| | |
| Deferred tax liabilities: | |
| | | |
| | |
| Digital assets | |
| (14,302 | ) | |
| (15,072 | ) |
| Depreciation of equipment | |
| (6,400 | ) | |
| (8,086 | ) |
| Total gross deferred liabilities | |
| (20,702 | ) | |
| (23,158 | ) |
| | |
| | | |
| | |
| Valuation allowance | |
| (9,263 | ) | |
| - | |
| Net deferred tax asset liabilities | |
| (7,404 | ) | |
| (6,471 | ) |
| | |
As of December 31, | |
| | |
2025 | | |
2024 | |
| | |
| | |
| |
| Deferred tax assets/(liabilities): | |
| | |
| |
| United States | |
| 7,158 | | |
| 7,158 | |
| Hong Kong | |
| 1,579 | | |
| - | |
| United Arab Emirates | |
| (1,213 | ) | |
| 1,443 | |
| Singapore | |
| (14,928 | ) | |
| (15,072 | ) |
| Net deferred tax assets/(liabilities) | |
| (7,404 | ) | |
| (6,471 | ) |
The Company has not identified any
uncertain tax positions requiring a reserve as of December 31, 2025, and 2024. The Company’s policy is to recognize interest and
penalties that would be assessed in relation to the settlement value of unrecognized tax benefits as a component of income tax expense.
The Company did not accrue either interest or penalties for the years ended December 31, 2025, and 2024.
As of December 31, 2025, the Company
has following tax Net Operating Losses (“NOLs”) that may be available to offset future taxable income:
| | | Gross amount | | | Expiring | | Deduction limitation | | | | | | | | | | | US-Federal | | | 31,965 | | | Indefinite* | | 80% of taxable income* | | US-State | | | 37,753 | | | Various | | 80% to 100% of taxable income | | Hong Kong | | | 867 | | | Indefinite | | No limitations |
| * | Under the Tax Cuts and Jobs Act, NOLs incurred after December 31, 2017 can be carried forward indefinitely, but may be limited in utilization to 80% of taxable income. |
Based on management’s evaluation
of all available positive and negative evidence, management concluded that it is more-likely-than-not that the Company will
not realize all its deferred tax assets in the United States. Accordingly, the Company recorded a valuation allowance to reduce
deferred tax assets to the amount expected to be realized
Changes in the valuation allowance
for deferred tax assets for the years ended December 31, 2025 are as follows:
| | |
Year ended
December 31,
2025 | |
| | |
| |
| Beginning balance | |
| - | |
Current
increase | |
| 9,263 | |
| Current decrease | |
| - | |
| Ending balance | |
| 9,263 | |
Upon adoption of ASU 2023-09, cash
paid for income taxes, net of refunds, during the year ended December 31, 2025 was as follows:
| | |
Year ended
December 31,
2025 | |
| | |
| |
| US-Federal | |
| - | |
| US-State | |
| 6 | |
| Foreign | |
| 924 | |
| Cash paid for income taxes (net of refunds) | |
| 930 | |
|