Table:
|  | 2019 | 2018 |
| --- | --- | --- |
| Deferred tax asset attributable to: |  |  |
| Net operating loss carryover | $3,839,000 | $2,290,000 |
| Stock compensation | 320,000 | 535,000 |
| Intangible Assets | - | 124,000 |
| Other | 36,000 | 3,000 |
| Deferred tax asset | 4,195,000 | $2,952,000 |
| Deferred tax liabilities attributable to: |  |  |
| Fixed assets | $(13,000) | $(5,000) |
| Intangibles | (2,438,000) | - |
| Other | (16,000) | (9,000) |
| Valuation allowance | (1,728,000) | (2,938,000) |
| Deferred tax liability | $(4,195,000) | $(2,952,000) |
| Net deferred tax asset | $- | $- |
Paragraphs:
NOTE 15 – INCOME TAXES (CONTINUED)
The cumulative tax effect of significant items comprising our net deferred tax amount at the expected rate of 21% is as follows as of December 31, 2019 and 2018:
The ultimate realization of deferred tax assets is dependent upon the Company’s ability to generate sufficient taxable income during the periods in which the net operating losses expire and the temporary differences become deductible. The Company has determined that there is significant uncertainty that the results of future operations and the reversals of existing taxable temporary differences will generate sufficient taxable income to realize the deferred tax assets; therefore, a valuation allowance has been recorded. In making this determination, the Company considered historical levels of income as well as projections for future periods.
The tax years 2016 to 2019 remain open for potential audit by the Internal Revenue Service. There are no uncertain tax positions as of December 31, 2018 or December 31, 2019, and none are expected in the next 12 months. The Company’s foreign subsidiaries are cost centers that are reimbursed for expenses, so generate no income or loss. Pretax book income (loss) is all from domestic operations. Up to four years of returns remain open for potential audit in foreign jurisdictions, however any audits for periods prior to ownership by the Company are the responsibility of the previous owners.
Under certain circumstances issuance of common shares can result in an ownership change under Internal Revenue Code Section 382, which limits the Company’s ability to utilize carry-forwards from prior to the ownership change. Any such ownership change resulting from stock issuances and redemptions could limit the Company’s ability to utilize any net operating loss carry-forwards or credits generated before this change in ownership. These limitations can limit both the timing of usage of these laws, as well as the loss of the ability to use these net operating losses. It is likely that fundraising activities have resulted in such an ownership change.
Question:
What is the ultimate realization of deferred tax assets dependent on?
Answer: the Company’s ability to generate sufficient taxable income during the periods in which the net operating losses expire and the temporary differences become deductible