AMERICAN TOWER CORP /MA/AMT
AMERICAN TOWER CORP /MA/ Income Taxes Disclosure
INCOME TAXES
Beginning in the taxable year ended December 31, 2012, the Company has filed, and intends to continue to file, U.S. federal income tax returns as a REIT, and its domestic TRSs filed, and intend to continue to file, separate tax returns as required. The Company also files tax returns in various states and countries. The Company’s state tax returns reflect different combinations of the Company’s subsidiaries and are dependent on the connection each subsidiary has with a particular state and form of organization. The following information refers to the Company’s income taxes on a consolidated basis.
The income tax provision from continuing operations consisted of the following:
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| Year Ended December 31, | |||||||||||||||||
| 2025 | 2024 | 2023 | |||||||||||||||
| Current: | |||||||||||||||||
| Federal (1) | $ | (37.6) | $ | (1.1) | $ | (1.0) | |||||||||||
| State | (7.1) | (8.0) | (4.9) | ||||||||||||||
| Foreign | (328.5) | (304.9) | (253.0) | ||||||||||||||
| Deferred: | |||||||||||||||||
| Federal (1) | (24.3) | (7.6) | 1.8 | ||||||||||||||
| State | (1.7) | (1.2) | 0.8 | ||||||||||||||
| Foreign | (16.5) | (43.5) | 165.5 | ||||||||||||||
| Income tax provision | $ | (415.7) | $ | (366.3) | $ | (90.8) | |||||||||||
(1)For the year ended December 31, 2025, includes impact of gains from equity securities in the U.S.
The effective tax rate (“ETR”) on income from continuing operations for the years ended December 31, 2025, 2024 and 2023 differs from the federal statutory rate primarily due to the Company’s qualification for taxation as a REIT, as well as adjustments for state and foreign items. As a REIT, the Company may deduct earnings distributed to stockholders against the income generated by its REIT operations.
On July 4, 2025, the One Big Beautiful Bill (“OBBB Act”), which includes a broad range of tax reform provisions, was signed into law in the United States. The OBBB Act did not have a material impact on the Company’s annual effective tax rate in 2025.
For the year ended December 31, 2025, the increase in the income tax provision was primarily attributable to (i) increased earnings in certain foreign jurisdictions, (ii) taxes incurred as a result of the sale of South Africa Fiber, (iii) additions to reserves for uncertain tax positions, (iv) gains from equity securities in the U.S. and (v) the reversal of permanent reinvestment assertions in Nigeria, partially offset by a net benefit from the application of tax law changes primarily in Germany and a decrease in withholding taxes from equity distributions due in part to the ATC TIPL Transaction (as defined in note 21).
For the year ended December 31, 2024, the increase in the income tax provision was primarily attributable to increased earnings in certain foreign jurisdictions, partially due to the impacts of the change in estimated useful lives on depreciation and amortization expense in the prior year and withholding taxes on equity distributions, including those related to the ATC TIPL Transaction (as defined in note 21), and management fees from certain foreign subsidiaries. The income tax provision for the year ended December 31, 2024, included the reversal of valuation allowances of $20.5 million in foreign and domestic jurisdictions as compared to the reversal of valuation allowances of $87.2 million for the year ended December 31, 2023. The income tax provision for the year ended December 31, 2023 also included a benefit from the application of a tax law change in Kenya.
Reconciliation between the U.S. statutory rate and the effective rate from continuing operations is as follows:
| Year Ended December 31, | |||||||||||||||||||||||||||||||||||
| 2025 | 2024 | 2023 | |||||||||||||||||||||||||||||||||
| Amount | % | Amount | % | Amount | % | ||||||||||||||||||||||||||||||
| Statutory tax rate | $ | 639.3 | 21.0 | % | $ | 761.2 | 21.0 | % | $ | 321.1 | 21.0 | % | |||||||||||||||||||||||
| State and local income tax, net of federal income tax effect (1) | 8.0 | 0.3 | % | 8.9 | 0.2 | % | 4.3 | 0.3 | % | ||||||||||||||||||||||||||
| Foreign taxes | |||||||||||||||||||||||||||||||||||
| Argentina | |||||||||||||||||||||||||||||||||||
| Foreign exchange | 2.2 | 0.1 | % | 6.5 | 0.2 | % | (23.0) | (1.5) | % | ||||||||||||||||||||||||||
| Other | (4.5) | (0.1) | % | (0.3) | (0.0) | % | 14.9 | 1.0 | % | ||||||||||||||||||||||||||
| Brazil | |||||||||||||||||||||||||||||||||||
| Withholding taxes | 36.9 | 1.2 | % | 49.4 | 1.4 | % | 32.9 | 2.1 | % | ||||||||||||||||||||||||||
| Other | 35.9 | 1.2 | % | (0.1) | (0.0) | % | 13.9 | 0.9 | % | ||||||||||||||||||||||||||
| Germany | |||||||||||||||||||||||||||||||||||
| Change in tax law | (84.6) | (2.8) | % | — | — | % | 5.6 | 0.4 | % | ||||||||||||||||||||||||||
| Other | 3.7 | 0.1 | % | 9.9 | 0.3 | % | 0.0 | 0.0 | % | ||||||||||||||||||||||||||
| Kenya | |||||||||||||||||||||||||||||||||||
| Change in tax law | — | — | % | — | — | % | (40.9) | (2.7) | % | ||||||||||||||||||||||||||
| Other | 9.4 | 0.3 | % | 3.8 | 0.1 | % | (7.0) | (0.5) | % | ||||||||||||||||||||||||||
| Mexico | |||||||||||||||||||||||||||||||||||
| Incremental loss on sale (2) | — | — | % | — | — | % | (143.0) | (9.4) | % | ||||||||||||||||||||||||||
| Change in valuation allowance | — | — | % | — | — | % | 168.9 | 11.0 | % | ||||||||||||||||||||||||||
| Other | 17.6 | 0.6 | % | 14.7 | 0.4 | % | 14.0 | 0.9 | % | ||||||||||||||||||||||||||
| Netherlands | |||||||||||||||||||||||||||||||||||
| Foreign tax credits | (102.1) | (3.4) | % | (66.9) | (1.8) | % | (62.5) | (4.1) | % | ||||||||||||||||||||||||||
| Change in valuation allowance | 61.2 | 2.0 | % | 52.7 | 1.5 | % | 31.5 | 2.1 | % | ||||||||||||||||||||||||||
| Rate differential between local and statutory tax rates | (1.4) | (0.0) | % | (13.5) | (0.4) | % | (17.4) | (1.1) | % | ||||||||||||||||||||||||||
| Other | 22.0 | 0.7 | % | (13.0) | (0.4) | % | 14.3 | 0.9 | % | ||||||||||||||||||||||||||
| Nigeria | |||||||||||||||||||||||||||||||||||
| Change in valuation allowance | — | — | % | — | — | % | (85.6) | (5.6) | % | ||||||||||||||||||||||||||
| Other | 60.4 | 2.0 | % | 20.2 | 0.6 | % | 19.4 | 1.3 | % | ||||||||||||||||||||||||||
| Singapore | |||||||||||||||||||||||||||||||||||
| Incremental loss on sale (2) | — | — | % | (146.3) | (4.0) | % | — | — | % | ||||||||||||||||||||||||||
| Change in valuation allowance | 0.1 | 0.0 | % | 146.3 | 4.0 | % | — | — | % | ||||||||||||||||||||||||||
| Other | (0.8) | (0.0) | % | 2.4 | 0.1 | % | 2.3 | 0.2 | % | ||||||||||||||||||||||||||
| Spain | |||||||||||||||||||||||||||||||||||
| Disallowance of goodwill impairment expense | — | — | % | — | — | % | 21.4 | 1.4 | % | ||||||||||||||||||||||||||
| Other | (1.1) | (0.0) | % | (2.4) | (0.1) | % | (5.4) | (0.4) | % | ||||||||||||||||||||||||||
| Other foreign jurisdictions | 58.0 | 1.9 | % | 80.0 | 2.2 | % | 41.9 | 2.7 | % | ||||||||||||||||||||||||||
| Changes in valuation allowance | 1.1 | 0.0 | % | (15.3) | (0.4) | % | 20.3 | 1.3 | % | ||||||||||||||||||||||||||
| Nontaxable or nondeductible | |||||||||||||||||||||||||||||||||||
| Adjustment to reflect REIT status (3) | (401.0) | (13.2) | % | (579.6) | (16.1) | % | (292.9) | (19.0) | % | ||||||||||||||||||||||||||
| Change in tax status (4) | — | — | % | 11.0 | 0.3 | % | (16.3) | (1.1) | % | ||||||||||||||||||||||||||
| Other | 0.5 | 0.0 | % | 6.1 | 0.2 | % | (4.2) | (0.3) | % | ||||||||||||||||||||||||||
| Changes in unrecognized tax benefits (5) | 54.9 | 1.8 | % | 30.6 | 0.8 | % | 62.3 | 4.1 | % | ||||||||||||||||||||||||||
| Effective tax rate | $ | 415.7 | 13.7 | % | $ | 366.3 | 10.1 | % | $ | 90.8 | 5.9 | % | |||||||||||||||||||||||
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(1)State taxes in Texas, Mississippi, Louisiana, New Hampshire, Oklahoma and Rhode Island made up the majority (greater than 50 percent) of the tax effect in this category.
(2)For the year ended December 31, 2024, Singapore includes amounts related to the sale of ATC TIPL (as defined in note 21). For the year ended December 31, 2023, Mexico includes amounts related to the sale of Mexico Fiber (as defined in note 15).
(3)As a result of the ability to utilize the dividends paid deduction to offset the Company’s REIT income and gains.
(4)As a result of a change in the election of previously designated TRSs to be included as part of the REIT.
(5)Includes both foreign and domestic unrecognized tax benefits.
Cash paid for income taxes, net of refunds consisted of the following:
| Year Ended December 31, | |||||||||||||||||
| 2025 | 2024 | 2023 | |||||||||||||||
| Federal (1) | $ | 29.2 | $ | 1.2 | $ | 3.1 | |||||||||||
| State | 8.9 | 4.6 | 5.9 | ||||||||||||||
| Foreign | 290.6 | 345.0 | 297.5 | ||||||||||||||
| Cash paid for income taxes, net of refunds | $ | 328.7 | $ | 350.8 | $ | 306.5 | |||||||||||
_______________
(1)For the year ended December 31, 2025, includes taxes paid related to the sale of equity securities in the U.S.
Cash paid for income taxes, net of refunds exceeded 5 percent of total income taxes paid, net of refunds in the following jurisdictions:
| Year Ended December 31, | |||||||||||||||||
| 2025 | 2024 | 2023 | |||||||||||||||
| Foreign | |||||||||||||||||
| Brazil | $ | 63.3 | $ | 76.8 | $ | 82.5 | |||||||||||
| Burkina Faso (1) | 18.6 | * | * | ||||||||||||||
| Ghana | 26.5 | * | 16.0 | ||||||||||||||
| India (2) | * | 73.6 | 53.1 | ||||||||||||||
| Kenya | * | * | 15.5 | ||||||||||||||
| Mexico | 25.0 | 43.8 | 36.6 | ||||||||||||||
| Nigeria | 17.9 | 27.7 | 30.8 | ||||||||||||||
| South Africa (1) | 39.3 | * | * | ||||||||||||||
| Uganda | 33.2 | 31.3 | * | ||||||||||||||
| Other | 66.8 | 91.8 | 63.0 | ||||||||||||||
| Total Foreign | $ | 290.6 | $ | 345.0 | $ | 297.5 | |||||||||||
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(*) Below threshold for period presented.
(1)For the year ended December 31, 2025, includes non-recurring tax payments.
(2)For the years ended December 31, 2024 and 2023, includes ATC TIPL (as defined in note 21).
The domestic and foreign components of income from continuing operations before income taxes are as follows:
| Year Ended December 31, | |||||||||||||||||
| 2025 | 2024 | 2023 | |||||||||||||||
| United States | $ | 2,141.3 | $ | 1,745.9 | $ | 1,371.4 | |||||||||||
| Foreign | 902.9 | 1,878.9 | 157.9 | ||||||||||||||
| Total | $ | 3,044.2 | $ | 3,624.8 | $ | 1,529.3 | |||||||||||
The components of the net deferred tax asset and liability and related valuation allowance were as follows:
| December 31, 2025 | December 31, 2024 | ||||||||||
| Assets: | |||||||||||
| Operating lease liability | $ | 992.2 | $ | 900.8 | |||||||
| Net operating loss carryforwards | 154.8 | 212.0 | |||||||||
| Accrued asset retirement obligations | 264.8 | 245.6 | |||||||||
| Stock-based compensation | 10.2 | 9.9 | |||||||||
| Unearned revenue | 24.5 | 19.8 | |||||||||
| Unrealized loss on foreign currency | 23.0 | 25.6 | |||||||||
| Other accruals, allowances and reserves | 157.1 | 46.1 | |||||||||
| Nondeductible interest | 55.1 | 51.6 | |||||||||
| Tax credits | 379.0 | 311.2 | |||||||||
| Capital loss carryforwards (1) | 311.7 | 293.1 | |||||||||
| Items not currently deductible and other | 9.6 | 58.6 | |||||||||
| Liabilities: | |||||||||||
| Depreciation and amortization | (1,673.0) | (1,566.0) | |||||||||
| Right-of-use asset | (994.5) | (907.0) | |||||||||
| Deferred rent | (143.3) | (116.3) | |||||||||
| Unremitted earnings of foreign subsidiaries | (50.6) | (11.1) | |||||||||
| Other | (49.2) | (31.5) | |||||||||
| Subtotal | (528.6) | (457.6) | |||||||||
| Valuation allowance | (760.3) | (681.7) | |||||||||
| Net deferred tax liabilities | $ | (1,288.9) | $ | (1,139.3) | |||||||
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(1)Includes amounts related to the sales of ATC TIPL (as defined in note 21) and Mexico Fiber (as defined in note 15).
The Company provides valuation allowances if, based on the available evidence, it is more likely than not that some or all of the deferred tax assets will not be realized. Management assesses the available evidence to estimate if sufficient future taxable income will be generated to use the existing deferred tax assets. Valuation allowances may be reversed if, based on changes in facts and circumstances, the net deferred tax assets have been determined to be realizable.
At December 31, 2025 and 2024, the Company has provided a valuation allowance of $760.3 million and $681.7 million, respectively, which primarily relates to foreign items. The increase in the valuation allowance for the year ending December 31, 2025 is due to uncertainty as to the timing of, and the Company’s ability to recover, net deferred tax assets in certain foreign operations in the foreseeable future, offset by reversals and fluctuations in foreign currency exchange rates. The amount of deferred tax assets considered realizable, however, could be adjusted if objective evidence in the form of cumulative losses is no longer present and additional weight may be given to subjective evidence such as the Company’s projections for growth.
A summary of the activity in the valuation allowance is as follows:
| 2025 | 2024 | 2023 | ||||||||||||||||||
| Balance as of January 1, | $ | 681.7 | $ | 433.5 | $ | 335.7 | ||||||||||||||
| Additions (1) | 61.9 | 305.6 | 249.1 | |||||||||||||||||
| Usage, expiration and reversals | (4.7) | (20.5) | (87.2) | |||||||||||||||||
| Foreign currency translation | 21.4 | (36.9) | (64.1) | |||||||||||||||||
| Balance as of December 31, | $ | 760.3 | $ | 681.7 | $ | 433.5 | ||||||||||||||
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(1)Includes net charges to expense and allowances established due to acquisition and divestitures.
The recoverability of the Company’s deferred tax assets has been assessed utilizing projections based on its current operations. Accordingly, the recoverability of the deferred tax assets is not dependent on material asset sales or other non-routine
transactions. Based on its current outlook of future taxable income during the carryforward period, the Company believes that deferred tax assets, other than those for which a valuation allowance has been recorded, will be realized.
The Company intends to reinvest foreign earnings indefinitely outside of the U.S., except for earnings in certain entities in Argentina, Brazil, Burkina Faso, Costa Rica, Jersey, Mexico, Netherlands, Nigeria, Paraguay, Singapore, South Africa, Spain, Uganda and the United Kingdom. Any tax consequences for future distributions from the entities that are not indefinitely reinvested have been recorded as deferred tax liabilities. It is not practicable to determine the amount of unrecognized deferred tax liability for outside basis differences in indefinitely reinvested entities.
At December 31, 2025, the Company had net federal, state and foreign operating loss carryforwards available to reduce future taxable income. If not utilized, the Company’s NOLs expire as follows:
| Years ended December 31, | Federal | State | Foreign | ||||||||||||||
| 2026 to 2030 | $ | 0.0 | $ | 136.8 | $ | 138.4 | |||||||||||
| 2031 to 2035 | 5.1 | 33.5 | 4.6 | ||||||||||||||
| 2036 to 2040 | 60.9 | 197.6 | 0.0 | ||||||||||||||
| 2041 to 2045 | — | 66.9 | 3.0 | ||||||||||||||
| Indefinite carryforward | 335.5 | 82.1 | 383.0 | ||||||||||||||
| Total | $ | 401.5 | $ | 516.9 | $ | 529.0 | |||||||||||
As of December 31, 2025 and 2024, the total amount of unrecognized tax benefits that would impact the ETR, if recognized, is $128.6 million and $101.3 million, respectively. The amount of unrecognized tax benefits for the year ended December 31, 2025 includes additions to the Company’s existing tax positions of $44.9 million.
A reconciliation of the beginning and ending amount of unrecognized tax benefits are as follows:
| Year Ended December 31, | |||||||||||||||||
| 2025 | 2024 | 2023 | |||||||||||||||
| Balance at January 1 | $ | 101.3 | $ | 116.9 | $ | 78.1 | |||||||||||
| Additions based on tax positions related to the current year | 24.1 | 3.4 | 42.4 | ||||||||||||||
| Additions and reductions for tax positions of prior years | 22.9 | 6.9 | 0.5 | ||||||||||||||
| Foreign currency | 10.2 | (14.4) | 3.9 | ||||||||||||||
| Reduction as a result of the lapse of statute of limitations | (13.7) | (2.3) | (2.1) | ||||||||||||||
| Reduction as a result of effective settlements | (16.2) | (9.2) | (5.9) | ||||||||||||||
| Balance at December 31 | $ | 128.6 | $ | 101.3 | $ | 116.9 | |||||||||||
During the year ended December 31, 2025, the statute of limitations on certain unrecognized tax benefits lapsed and certain positions were effectively settled, including effective settlements and revisions of prior year positions, which resulted in a decrease of $27.8 million in the liability for unrecognized tax benefits. During the year ended December 31, 2024, the statute of limitations on certain unrecognized tax benefits lapsed and certain positions were effectively settled, including effective settlements and revisions of prior year positions, which resulted in a decrease of $12.8 million in the liability for unrecognized tax benefits. During the year ended December 31, 2023, the statute of limitations on certain unrecognized tax benefits lapsed and certain positions were effectively settled, including effective settlements and revisions of prior year positions, which resulted in a decrease of $15.5 million in the liability for unrecognized tax benefits.
The Company recorded penalties and tax-related interest expense to the tax provision of $29.3 million, $28.6 million and $21.8 million for the years ended December 31, 2025, 2024 and 2023, respectively. During the years ended December 31, 2025, 2024 and 2023, the Company reduced its liability for penalties and income tax-related interest expense related to uncertain tax positions by $8.3 million, $10.4 million and $9.7 million, respectively, due to the expiration of the statute of limitations in certain jurisdictions and certain positions that were effectively settled.
As of December 31, 2025 and 2024, the total amount of accrued income tax-related interest and penalties included in the consolidated balance sheets were $86.8 million and $58.5 million, respectively.
The Company has filed for prior taxable years, and for its taxable year ended December 31, 2025 will file, numerous consolidated and separate income tax returns, including U.S. federal and state tax returns and foreign tax returns. The Company is subject to examination in the United States and various state and foreign jurisdictions for certain tax years. As a result of the
Company’s ability to carryforward federal, state and foreign NOLs, the applicable tax years generally remain open to examination several years after the applicable loss carryforwards have been used or have expired. The Company regularly assesses the likelihood of additional assessments in each of the tax jurisdictions resulting from these examinations.
Historical Timeline
| Fiscal Year | Filed | |
|---|---|---|
| 2025 | Feb 24, 2026 | Showing above |
| 2024 | Feb 25, 2025 | |
| 2023 | Feb 27, 2024 | |
| 2022 | Feb 23, 2023 | |
| 2021 | Feb 25, 2022 | |
| 2020 | Feb 25, 2021 | |
| 2019 | Feb 25, 2020 | |
| 2018 | Feb 27, 2019 | |
| 2017 | Feb 28, 2018 | |
| 2016 | Feb 27, 2017 | |
| 2015 | Feb 26, 2016 | |
About Income Taxes Disclosures
The income tax disclosure reveals how much a company actually pays in taxes versus what the statutory rate would predict. Analysts focus on the effective tax rate (ETR) reconciliation, which breaks down every item driving the gap between the 21% federal rate and the company's reported ETR — including R&D credits, foreign rate differentials, and state taxes. Deferred tax assets (DTAs) and their valuation allowances signal management's confidence in future profitability: a rising allowance suggests the company doubts it can use accumulated tax benefits. Uncertain tax benefit (UTB) reserves quantify exposure to IRS challenges on aggressive positions.
Key signals to watch: sudden ETR drops without clear operational reasons, large increases in valuation allowances, growing UTB balances, and significant unremitted foreign earnings. Post-TCJA, pay attention to GILTI and BEAT provisions that affect multinational tax structures. Compare the cash taxes paid (from the cash flow statement) against the income tax provision to gauge earnings quality.