11. INCOME TAXES
The Company’s effective income tax rate is dependent on many factors, including the estimated nature and amounts of income and expenses allocated to the non-controlling interests without being subject to federal, state and local income taxes at the corporate level. Additionally, the Company’s effective tax rate is influenced by the amount of income tax provision recorded for any affiliated funds and co-investment vehicles that are consolidated in the Company’s consolidated financial statements.
The Company files its tax returns as prescribed by the tax laws of the jurisdictions in which it operates. In the normal course of business, the Company is subject to examination by U.S. federal, state, local and foreign tax authorities. With limited exceptions, the Company is no longer subject to income tax audits by taxing authorities for any years prior to 2021. Although the outcome of tax audits is always uncertain, the Company does not believe the outcome of any future audit will have a material adverse effect on the Company’s consolidated financial statements.
The provision for income taxes attributable to the Company and the Consolidated Funds, consisted of the following:
| | | | | | | | | | | | | | | | | | | | |
| | | Year ended December 31, |
| Provision for Income Taxes | | 2025 | | 2024 | | 2023 |
| The Company | | | | | | |
| Current | | | | | | |
| U.S. federal income tax expense | | $ | 55,531 | | | $ | 63,292 | | | $ | 34,051 | |
| State and local income tax expense | | 15,456 | | | 14,326 | | | 13,316 | |
| Foreign income tax expense | | 44,869 | | | 24,841 | | | 24,029 | |
| | 115,856 | | | 102,459 | | | 71,396 | |
| Deferred | | | | | | |
| U.S. federal income tax expense | | 87,010 | | | 50,182 | | | 85,610 | |
| State and local income tax expense | | 12,370 | | | 7,819 | | | 15,872 | |
| Foreign income tax benefit | | (22,829) | | | (2,917) | | | (3,730) | |
| | 76,551 | | | 55,084 | | | 97,752 | |
| Total | | | | | | |
| U.S. federal income tax expense | | 142,541 | | | 113,474 | | | 119,661 | |
| State and local income tax expense | | 27,826 | | | 22,145 | | | 29,188 | |
| Foreign income tax expense | | 22,040 | | | 21,924 | | | 20,299 | |
| Income tax expense | | 192,407 | | | 157,543 | | | 169,148 | |
| | | | | | |
| Consolidated Funds | | | | | | |
| Current | | | | | | |
| | | | | | |
| | | | | | |
| Foreign income tax expense (benefit) | | (434) | | | (1,331) | | | 3,823 | |
| | (434) | | | (1,331) | | | 3,823 | |
| Deferred | | | | | | |
| U.S. federal income tax expense | | 6,562 | | | 8,405 | | | — | |
| | | | | | |
| | | | | | |
| | 6,562 | | | 8,405 | | | — | |
| Total | | | | | | |
| U.S. federal income tax expense | | 6,562 | | | 8,405 | | | — | |
| | | | | | |
| Foreign income tax expense (benefit) | | (434) | | | (1,331) | | | 3,823 | |
| Income tax expense | | 6,128 | | | 7,074 | | | 3,823 | |
| | | | | | |
| Total Provision for Income Taxes | | | | | | |
| Total current income tax expense | | 115,422 | | | 101,128 | | | 75,219 | |
| Total deferred income tax expense | | 83,113 | | | 63,489 | | | 97,752 | |
| Income tax expense | | $ | 198,535 | | | $ | 164,617 | | | $ | 172,971 | |
The disaggregation of income before taxes is effective with the adoption of ASU 2023-09 and consisted of the following:
| | | | | | | | | | | | |
| | | Year ended December 31, 2025 |
| | | | | | |
| U.S. | | $ | 1,102,366 | | | | | |
| Foreign | | 184,527 | | | | | |
| Total | | $ | 1,286,893 | | | | | |
The reconciliation of taxes from the statutory tax rate to the Company’s effective tax rate changed with the adoption of ASU 2023-09 and is presented below:
| | | | | | | | | | | | | | | | | | | | | | |
| | Year ended December 31, 2025 |
| | | | | | |
| U.S. federal statutory rate | | $ | 270,248 | | | 21.0 | % | | | | | | | | |
State and local taxes, net of federal benefit(1) | | 24,214 | | | 1.9 | | | | | | | | | |
| Effect of cross-border tax laws: | | | | | | | | | | | | |
| | | | | | | | | | | | |
| United Kingdom | | 15,601 | | | 1.2 | | | | | | | | | |
| Japan | | 15,187 | | | 1.2 | | | | | | | | | |
| Singapore | | 5,214 | | | 0.4 | | | | | | | | | |
| Other jurisdictions | | 6,673 | | | 0.5 | | | | | | | | | |
| | | | | | | | | | | | |
| Foreign tax effects | | | | | | | | | | | | |
| United Kingdom: | | | | | | | | | | | | |
| Statutory tax rate differential | | 3,046 | | | 0.2 | | | | | | | | | |
| Other rate differential items | | (16,343) | | | (1.3) | | | | | | | | | |
| Japan: | | | | | | | | | | | | |
| Statutory tax rate differential | | 2,800 | | | 0.2 | | | | | | | | | |
| Other rate differential items | | (8,377) | | | (0.7) | | | | | | | | | |
| Singapore: | | | | | | | | | | | | |
| Statutory tax rate differential | | (4,698) | | | (0.4) | | | | | | | | | |
| Other rate differential items | | 5,833 | | | 0.5 | | | | | | | | | |
| Other foreign jurisdictions: | | | | | | | | | | | | |
| Statutory tax rate differential | | 1,339 | | | 0.1 | | | | | | | | | |
| Other rate differential items | | (4,223) | | | (0.3) | | | | | | | | | |
| | | | | | | | | | | | |
| Tax credits | | | | | | | | | | | | |
| Foreign tax credits | | (12,864) | | | (1.0) | | | | | | | | | |
| Research and development tax credits | | (699) | | | (0.1) | | | | | | | | | |
| Other business tax credits | | (1,702) | | | (0.1) | | | | | | | | | |
| | | | | | | | | | | | |
| Changes in valuation allowance | | (950) | | | (0.1) | | | | | | | | | |
| | | | | | | | | | | | |
| Nontaxable or nondeductible items | | | | | | | | | | | | |
| Nondeductible executive compensation expense | | 19,710 | | | 1.5 | | | | | | | | | |
| Other, net | | 2,874 | | | 0.2 | | | | | | | | | |
| | | | | | | | | | | | |
| Other adjustments | | | | | | | | | | | | |
| Income passed through to non-controlling interests | | (124,348) | | | (9.6) | | | | | | | | | |
| | | | | | | | | | | | |
| | | | | | | | | | | | |
| | | | | | | | | | | | |
| | | | | | | | | | | | |
| | | | | | | | | | | | |
| Effective tax rate | | $ | 198,535 | | | 15.3 | % | | | | | | | | |
(1)State taxes in California and New York and local taxes New York City comprise the majority of the state and local taxes, net of federal benefit.
The reconciliation of the statutory tax rate to the Company’s effective tax rate for periods prior to the adoption of ASU 2023-09 is as follows:
| | | | | | | | | | | | | | |
| | | Year ended December 31, |
| | | 2024 | | 2023 |
| Income tax expense at federal statutory rate | | 21.0% | | 21.0% |
| Income passed through to non-controlling interests | | (9.3) | | (9.6) |
| State and local taxes, net of federal benefit | | 1.4 | | 1.7 |
| Foreign taxes | | (0.7) | | (0.7) |
| Permanent items | | 0.1 | | 0.2 |
| Disallowed executive compensation | | 0.3 | | 0.2 |
| Other, net | | 0.1 | | 0.3 |
| Valuation allowance | | — | | (0.1) |
| Total effective rate | | 12.9% | | 13.0% |
The disaggregated presentation of income taxes paid that is effective with the adoption of ASU 2023-09 is presented below:
| | | | | | | | | | | | |
| | | Year ended December 31, 2025 |
| | | | | | |
| Federal income tax | | $ | 35,700 | | | | | |
| State and local income tax | | 26,777 | | | | | |
| Foreign income tax | | 28,856 | | | | | |
| Total | | $ | 91,333 | | | | | |
The following jurisdictions represent approximately 5% of total income taxes paid (net of refunds), or if less than 5%, represent the largest jurisdictions:
| | | | | | | | | | | | |
| | Year ended December 31, 2025 |
| | | | | | |
| State and local income tax | | | | | | |
| New York | | $ | 3,415 | | | | | |
| New York City | | 10,702 | | | | | |
| California | | 3,941 | | | | | |
| | | | | | |
| Foreign income tax | | | | | | |
| United Kingdom | | $ | 14,426 | | | | | |
| Japan | | 5,419 | | | | | |
Deferred Taxes
The income tax effects of temporary differences that give rise to significant portions of deferred tax assets and liabilities were as follows as of December 31, 2025 and 2024. Deferred tax assets, net of the Company are included within other assets within the Consolidated Statements of Financial Condition. Deferred tax liabilities, net of the Consolidated Funds are included within accounts payable, accrued expenses and other liabilities within the Consolidated Statements of Financial Condition.
| | | | | | | | | | | | | | |
| | | As of December 31, |
| Deferred Tax Assets and Liabilities of the Company | | 2025 | | 2024 |
| Deferred tax assets | | | | |
| Amortizable tax basis for AOG Unit exchanges | | $ | 638,725 | | | $ | 451,343 | |
| | | | |
| Net operating losses and capital loss carryforwards | | 34,415 | | | 1,888 | |
| Other, net | | 30,708 | | | 9,793 | |
| Total gross deferred tax assets | | 703,848 | | | 463,024 | |
| Valuation allowance | | (941) | | | (941) | |
| Total net deferred tax assets | | 702,907 | | | 462,083 | |
| Deferred tax liabilities | | | | |
| Investment in partnerships | | (350,616) | | | (220,189) | |
| | | | |
| Total deferred tax liabilities | | (350,616) | | | (220,189) | |
| Deferred tax assets, net | | $ | 352,291 | | | $ | 241,894 | |
| | | | | | | | | | | | | | |
| | | As of December 31, |
| Deferred Tax Assets and Liabilities of the Consolidated Funds | | 2025 | | 2024 |
| Deferred tax assets | | | | |
| Net operating losses | | $ | 9,295 | | | $ | 7,932 | |
| | | | |
| Total gross deferred tax assets | | 9,295 | | | 7,932 | |
| Valuation allowance | | (279) | | | (1,229) | |
| Total net deferred tax assets | | 9,016 | | | 6,703 | |
| Deferred tax liabilities | | | | |
| Investments in partnerships | | (23,984) | | | (15,108) | |
| Total deferred tax liabilities | | (23,984) | | | (15,108) | |
| Deferred tax liabilities, net | | $ | (14,968) | | | $ | (8,405) | |
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In assessing the realizability of deferred tax assets, the Company considers whether it is probable that some or all of the deferred tax assets will not be realized. In determining whether the deferred taxes are realizable, the Company considers the period of expiration of the tax asset, historical and projected taxable income, and tax liabilities for the tax jurisdiction in which the tax asset is located. Valuation allowances are provided to reduce the amounts of deferred tax assets to an amount that is more likely than not to be realized based on an assessment of positive and negative evidence, including estimates of future taxable income necessary to realize future deductible amounts.
As of December 31, 2025 and 2024, the Company had net operating loss (“NOLs”) carryforwards in the United States and foreign jurisdictions associated with its subsidiaries. As of December 31, 2025 and 2024, the Company had $99.0 million and $7.6 million, respectively, of NOL carryforwards and other tax attributes related to its foreign jurisdictions to reduce future income taxes. With limited exceptions, the deferred tax assets related to operating losses in foreign jurisdictions and certain capital loss carryforwards meet the more likely than not threshold and do not have a valuation allowance recorded for the net balance. As of December 31, 2025 and 2024, the valuation allowance for the Company’s deferred tax assets was $0.9 million, associated with NOLs in certain foreign jurisdictions.
As of December 31, 2025 and 2024, the Consolidated Funds had $42.7 million and $36.4 million, respectively, of NOL carryforwards and other tax attribute to reduce future income taxes for which a partial valuation allowance has been provided. As of December 31, 2025 and 2024, the valuation allowance for the deferred tax assets of the Consolidated Funds was $0.3 million and $1.2 million, respectively, associated with NOL carryforwards related to its Consolidated funds. The NOL carryforwards generally have no expiry.
As of, and for the years ended December 31, 2025, 2024 and 2023, the Company had no significant uncertain tax positions.