NOTE INCOME TAXES

 UK and various US state jurisdictions. The Company’s tax years for and forward are subject to examination by the US and state tax authorities due to losses incurred since inception. The Company is currently under any material examination by any taxing authorities.

740

10,

, that defines a recognition threshold and measurement attributes for the financial recognition and measurement of a tax position taken or expected to be taken in a tax return. ASC - also provides guidance on the de-recognition, classification, interest and penalties, accounting in interim periods, disclosure, and transition. Under ASC - the impact of an uncertain income tax position on the income tax return must be recognized at the largest amount that is more-likely-than- to be sustained upon audit by the relevant taxing authority. An uncertain income tax position will be recognized if it has less than a likely of being sustained.

not

’s practice is to recognize interest and/or penalties related to income matters in income tax expense. During the year ended the Company recognized penalties of million. There were interest and penalties recognized by the Company for the year ended

loss) before income taxes for the years ended and was taxed under the following jurisdictions (in thousands):

June 30,

201

and (in thousands):

2016

  As of prior to the adoption of ASU - the Company had excess tax benefits for which benefits could be previously recognized of approximately million, due to net operating loss carryforwards resulting from the windfall tax benefits.  On upon the effective date of the adoption, the Company recognized the previously unrecognized excess tax benefits of million with an offsetting increase in the Company’s valuation allowance using a modified retrospective method through a cumulative effect adjustment to the accumulated deficit, with net impact on the Company’s financial statements.

June 30,

201

the Company had net US deferred tax assets of approximately million. Due to uncertainties surrounding the Company’s ability to generate future capital gains, a valuation allowance has been established to offset carry-forwards of its capital losses due to investments previously written off. Additionally, the future utilization of the Company’s federal and state NOLs to offset future taxable income have been determined to be subject to annual limitation pursuant to Internal Revenue Code (“IRC”) Sections and as a result of ownership changes that have previously occurred.

382

382.

June 30, 2011,

$0.

million of previously incurred NOLs; presuming, however, there is taxable income in future periods affording utilization prior to expiration.

June 30,

201

the Company had combined federal and state NOLs of approximately million and million, respectively. The federal and state tax loss carry-forwards will begin to expire in and respectively, unless previously utilized.

’s net deferred tax assets at and are shown below. A valuation allowance of million and million has been established to offset the net deferred tax assets as of and respectively. The million net decrease in the valuation allowance for the year ended is primarily attributable to the partial release of the valuation allowance during the months ended The Company released the valuation allowance on all of its domestic deferred tax assets, except for capital loss carry-forwards that are more likely than to be realized.

’s current year tax benefit for the change in valuation allowance of is the excess tax benefit of million. 

June 30,

201

and (in thousands):

(benefit) for income taxes for the years ended and differs from the amount computed by applying the US federal income tax rates to net income from continuing operations before taxes as a result of the following (in thousands):

June 30, 2016,

$0.2