12. Income Taxes

The Company has the following net deferred tax assets and liabilities at December 31, 2020 and 2019:

The benefit for income taxes for the years ended December 31, 2020 and 2019 consists of the following:

A reconciliation of the statutory federal income tax rate to the Company’s effective tax rate is as follows:

The valuation allowance at December 31, 2020 was approximately $8,637,000. The net change in the valuation allowance during the year ended December 31, 2020 was an increase of approximately $895,000. In assessing the realizability of deferred tax assets, management considers whether it is more likely than not that some portion or all of the deferred income tax assets will not be realized. The ultimate realization of deferred income tax assets is dependent upon the generation of future taxable income during the periods in which those temporary differences become deductible. Management considers the scheduled reversal of deferred income tax liabilities, projected future taxable income, and tax planning strategies in making this assessment. Based on consideration of these items, management has determined that enough uncertainty exists relative to the realization of the deferred income tax asset balances to warrant the application of a valuation allowance as of December 31, 2020.

At December 31, 2020, the Company had net operating loss carryforwards for federal and state income tax purposes of approximately $29,584,000. Of this amount, $20,476,000 expires between 2034 and 2038, and $9,108,000 has an indefinite carryforward period. Certain tax attributes are subject to an annual limitation as a result of changes in ownership as defined under Internal Revenue Code Section 382. The Company files tax returns in multiple jurisdictions and is subject to examination in these jurisdictions. Significant jurisdictions in the U.S. include New York, Illinois and California.

The U.S. Tax Cuts and Jobs Act of 2017 provided for a one-time deemed mandatory repatriation of post-1986 undistributed foreign E&P through the year ended December 31, 2017. The Company had an estimated $332,000 of undistributed foreign E&P subject to the deemed mandatory repatriation, this income was offset by U.S. operating losses. As of December 31, 2020, foreign withholding taxes have not been provided on the undistributed E&P of its foreign subsidiaries as the Company intend to permanently reinvest these foreign earnings in those businesses outside the U.S.

Beginning in 2018, the Tax Act includes a new U.S. tax base erosion provision designed to tax the global intangible low-taxed income (“GILTI”). The GILTI provisions require us to include in our U.S. income tax return foreign subsidiary earnings in excess of an allowable return on the foreign subsidiary’s tangible assets. The Company has elected to recognize the tax on GILT as a period expense in the period the tax is incurred.