Notes to Consolidated Financial Statements
For the years ended December 31, 2014 and 2013
- Cameco Corporation
- Significant accounting policies
- Accounting standards
- Determination of fair values
- Use of estimates and judgments
- Discontinued operation
- Acquisitions
- Accounts receivable
- Inventories
- Property, plant and equipment
- Goodwill and intangible assets
- Long-term receivables, investments and other
- Equity-accounted investees
- Accounts payable and accrued liabilities
- Short-term debt
- Long-term debt
- Other liabilities
- Provisions
- Share capital
- Employee benefit expense
- Finance costs
- Other income (expense)
- Income taxes
- Per share amounts
- Statements of cash flows
- Share-based compensation plans
- Pension and other post-retirement benefits
- Financial instruments and related risk management
- Capital management
- Segmented information
- Group entities
- Joint operations
- Related parties
- Subsequent event
23. Income taxes
-
A. Significant components of deferred tax assets and liabilities
Recognized in earnings As at December 31 2014 2013 2014 2013 Assets Inventories $ — $(3,250) $ — $ — Provision for reclamation 75,752 9,084 251,045 174,708 Foreign exploration and development (807) (2,711) 6,103 6,910 Income tax losses 136,294 73,412 335,856 199,412 Defined benefit plan actuarial losses — — 5,813 8,807 Long-term investments and other 1,424 8,672 67,060 59,628 Deferred tax assets 212,643 85,207 665,877 449,465 Liabilities Property, plant and equipment (1,334) (42,994) 182,841 184,930 Inventories (15,719) (15,825) 20,590 37,139 Other (3,102) (24,918) — 3,102 Deferred tax liabilities (20,155) (83,737) 203,431 225,171 Net deferred tax asset $232,798 $168,944 $462,446 $224,294
Deferred tax allocated as 2014 2013 Deferred tax assets $486,328 $266,203 Deferred tax liabilities (23,882) (41,909) Net deferred tax asset $462,446 $224,294 Based on projections of future income, realization of these deferred tax assets is probable and consequently a deferred tax asset has been recorded.
-
B. Movement in net deferred tax assets and liabilities
2014 2013 Net deferred tax asset at beginning of year $224,294 $188,143 Deferred tax liability on acquisition of NUKEM — (52,964) Recovery for the year in net earnings 246,558 185,830 Expense on discontinued operations (13,761) (16,886) Recovery (expense) for the year in other comprehensive income 3,171 (79,427) Foreign exchange adjustments 2,184 (402) End of year $462,446 $224,294 -
C. Significant components of unrecognized deferred tax assets
2014 2013 Income tax losses $130,300 $72,656 Property, plant and equipment 1,404 54,759 Long-term investments and other 85,927 12,539 Total $217,631 $139,954 -
D. Tax rate reconciliation
The provision for income taxes differs from the amount computed by applying the combined expected federal and provincial income tax rate to earnings before income taxes. The reasons for these differences are as follows:
2014 2013 Earnings from continuing operations before income taxes and non-controlling interest $(119,098) $115,136 Combined federal and provincial tax rate 26.9% 26.9% Computed income tax expense (32,037) 30,972 Increase (decrease) in taxes resulting from: Difference between Canadian rates and rates applicable to subsidiaries in other countries (225,368) (200,877) Change in unrecognized deferred tax assets 76,009 11,297 Other taxes 3,430 3,332 Share-based compensation plans 2,094 3,580 Change in tax provision related to transfer pricing 12,000 10,000 Non-deductible (non-taxable) capital amounts (8,108) 18,328 Other permanent differences (3,288) 6,138 Income tax recovery $(175,268) $(117,230) -
E. Reassessments
In 2008, as part of the ongoing annual audits of Cameco’s Canadian tax returns, Canada Revenue Agency (CRA) disputed the transfer pricing structure and methodology used by Cameco and its wholly owned Swiss subsidiary, Cameco Europe Ltd., in respect of sale and purchase agreements for uranium products. From December 2008 to date, CRA issued notices of reassessment for the taxation years 2003 through 2009, which in aggregate have increased Cameco’s income for Canadian tax purposes by approximately $2,795,000,000. CRA has also issued notices of reassessment for transfer pricing penalties for the years 2007 through 2009 in the amount of $229,300,000. Cameco believes it is likely that CRA will reassess Cameco’s tax returns for subsequent years on a similar basis and that these will require Cameco to make future remittances on receipt of the reassessments.
Using the methodology we believe that CRA will continue to apply and including the $2,795,000,000 already reassessed, we expect to receive notices of reassessment for a total of approximately $6,600,000,000 for the years 2003 through 2014, which would increase Cameco’s income for Canadian tax purposes and result in a related tax expense of approximately $1,900,000,000. In addition to penalties already imposed, CRA may continue to apply penalties to taxation years subsequent to 2009. As a result, we estimate that cash taxes and transfer pricing penalties would be between $1,450,000,000 and $1,500,000,000. In addition, we estimate there would be interest and instalment penalties applied that would be material to Cameco. While in dispute, we would be responsible for remitting 50% of the cash taxes and transfer pricing penalties (between $725,000,000 and $750,000,000), plus related interest and instalment penalties assessed, which would be material to Cameco.
Under Canadian federal and provincial tax rules, the amount required to be remitted each year will depend on the amount of income reassessed in that year and the availability of elective deductions and tax loss carryovers. In light of our view of the likely outcome of the case, we expect to recover the amounts remitted to CRA, including cash taxes, interest and penalties totalling $211,604,000 already paid as at December 31, 2014 (December 31, 2013 – $59,475,000) (note 12).
The case on the 2003 reassessment is expected to go to trial in 2016. If this timing is adhered to, we expect to have a Tax Court decision within six to 18 months after the trial is complete.
Having regard to advice from its external advisors, Cameco’s opinion is that CRA’s position is incorrect and Cameco is contesting CRA’s position and expects to recover any amounts remitted as a result of the reassessments. However, to reflect the uncertainties of CRA’s appeals process and litigation, Cameco has recorded a cumulative tax provision related to this matter for the years 2003 through the current period in the amount of $85,000,000. While the resolution of this matter may result in liabilities that are higher or lower than the reserve, management believes that the ultimate resolution will not be material to Cameco’s financial position, results of operations or liquidity in the year(s) of resolution. Resolution of this matter as stipulated by CRA would be material to Cameco’s financial position, results of operations or liquidity in the year(s) of resolution and other unfavourable outcomes for the years 2003 to date could be material to Cameco’s financial position, results of operations and cash flows in the year(s) of resolution.
Further to Cameco’s decision to contest CRA’s reassessments, Cameco is pursuing its appeal rights under Canadian federal and provincial tax rules.
-
F. Earnings and income taxes by jurisdiction
2014 2013 Earnings (loss) from continuing operations before income taxes Canada $(840,705) $(715,361) Foreign 721,607 830,497 $(119,098) $115,136 Current income taxes Canada $(2,944) $3,087 Foreign 74,234 65,513 $71,290 $68,600 Deferred income tax recovery Canada $(209,255) $(150,474) Foreign (37,303) (35,356) $(246,558) $(185,830) Income tax recovery $(175,268) $(117,230) -
G. Income tax losses
At December 31, 2014, income tax losses carried forward of $1,632,194,000 (2013 – $968,347,000) are available to reduce taxable income. These losses expire as follows:
Date of expiry Canada US Other Total 2019 $ — $ — $4,686 $4,686 2020 — — 2,637 2,637 2029 — 23,839 — 23,839 2030 — 1,393 — 1,393 2031 94,257 20,332 — 114,589 2032 213,871 20,065 — 233,936 2033 252,781 34,206 — 286,987 2034 300,182 24,029 — 324,211 No expiry — — 639,916 639,916 $861,091 $123,864 $647,239 $1,632,194 Included in the table above is $434,051,000 (2013 – $244,845,000) of temporary differences related to loss carry forwards where no future benefit is realized.
-
H. Other comprehensive income
Other comprehensive income included on the consolidated statements of comprehensive income and the consolidated statements of changes in equity is presented net of income taxes. The following income tax amounts are included in each component of other comprehensive income:
For the year ended December 31, 2014 Before tax Income tax
recovery
(expense)Net of tax Remeasurements of defined benefit liability $(10,930) $2,978 $(7,952) Exchange differences on translation of foreign operations 58,890 — 58,890 Gains on derivatives designated as cash flow hedges transferred to net earnings – discontinued operation (400) 100 (300) Unrealized losses on available-for-sale assets (707) 94 (613) Losses on available-for-sale assets transferred to net earnings 3 (1) 2 $46,856 $3,171 $50,027
For the year ended December 31, 2013 Before tax Income tax
recovery
(expense)Net of tax Remeasurements of defined benefit liability $2,585 $(715) $1,870 Remeasurements of defined benefit liability – discontinued operation 319,887 (79,972) 239,915 Exchange differences on translation of foreign operations (10,972) — (10,972) Gains on derivatives designated as cash flow hedges – discontinued operation 253 (63) 190 Gains on derivatives designated as cash flow hedges transferred to net earnings – discontinued operation (5,309) 1,327 (3,982) Unrealized gains on available-for-sale-assets 32 (4) 28 $306,656 $(79,427) $227,229