Income Taxes
The components of income before income taxes were as follows:
| | | | | | | | | | | | | | | | | |
| 2025 | | 2024 | | 2023 |
| U.S. | $ | 149 | | | $ | (448) | | | $ | (1) | |
| Foreign | 1,011 | | | 1,191 | | | 796 | |
| $ | 1,160 | | | $ | 743 | | | $ | 795 | |
The provision for income taxes consisted of the following:
| | | | | | | | | | | | | | | | | |
| 2025 | | 2024 | | 2023 |
| Current tax: | | | | | |
| U.S. federal | $ | 19 | | | $ | 89 | | | $ | 31 | |
| U.S. state | 4 | | | 7 | | | 8 | |
| Foreign | 218 | | | 255 | | | 236 | |
| $ | 241 | | | $ | 351 | | | $ | 275 | |
| Deferred tax: | | | | | |
| U.S. federal | $ | 6 | | | $ | (109) | | | $ | (27) | |
| U.S. state | 5 | | | (17) | | | (6) | |
| Foreign | 29 | | | (42) | | | (20) | |
| 40 | | | (168) | | | (53) | |
| Total | $ | 281 | | | $ | 183 | | | $ | 222 | |
The provision for income taxes differs from the amount of income tax determined by applying the U.S. statutory federal income tax rate to pre-tax income as a result of the following items:
| | | | | | | | | | | |
| 2025 |
| | Amount | | Percentage |
| U.S. statutory rate at 21% | $ | 244 | | | 21% |
| State taxes (a) | 9 | | | 0.8 |
| Foreign Tax Effects | | | |
| Brazil | | | |
| Tax incentives | (13) | | | (1.1) |
| Other | (5) | | | (0.4) |
| Mexico | | | |
| Statutory tax rate difference | 18 | | | 1.6 |
| Other | (2) | | | (0.2) |
| France | | | |
| Valuation allowance changes | 16 | | | 1.3 |
| Other | 1 | | | 0.1 |
| Foreign withholding taxes | 11 | | | 0.9 |
| Other | 18 | | | 1.6 |
| Effect of cross-border tax laws | | | |
| Global Intangible Low-Taxed Income, net of credits | 12 | | | 1.0 |
| Foreign source income | (26) | | | (2.2) |
| Other | (8) | | | (0.7) |
| Nontaxable or nondeductible items | 8 | | | 0.7 |
| | | |
| Change in unrecognized tax benefits | (2) | | | (0.2) |
| | | |
| Income tax provision | $ | 281 | | | 24.2% |
| | | |
| (a) The states that contribute to the majority (greater than 50%) of the effect of this category include Illinois, Minnesota, Pennsylvania, Virginia and Wisconsin. |
In the first quarter of 2025, the Company recognized an income tax benefit of $22, included in foreign source income above, after an internal reorganization which resulted in the release of deferred tax liabilities related to the foreign currency impact of certain intercompany debt instruments that were designated as hedges of the Company’s net investment in a euro-based subsidiary.
As of December 31, 2025, the Company has not provided deferred taxes on earnings in certain non-U.S. subsidiaries because such earnings are indefinitely reinvested in its international operations. Upon distribution of such earnings in the form of dividends or otherwise, the Company may be subject to incremental foreign tax. It is not practicable to estimate the amount of foreign tax that might be payable.
| | | | | | | | | | | |
| | 2024 | | 2023 |
| U.S. statutory rate at 21% | $ | 156 | | | $ | 167 | |
| Statutory tax rate differences | (17) | | | 6 | |
| Taxes on foreign income | (30) | | | 1 | |
| Foreign withholding taxes | 19 | | | 23 | |
| U.S. taxes on foreign income, net of credits | 67 | | | 5 | |
| State taxes | (12) | | | 2 | |
| Valuation allowance changes | (17) | | | 5 | |
| Tax contingencies | 6 | | | 2 | |
| Tax law changes | 5 | | | 8 | |
| Other items, net | 6 | | | 3 | |
| Income tax provision | $ | 183 | | | $ | 222 | |
The Company benefits from certain incentives in Brazil which allow it to pay reduced income taxes. The incentives expire at various dates beginning in December 2026. These incentives increased net income attributable to the Company by $21 in 2025, $22 in 2024, and $20 in 2023.
In the fourth quarter of 2024, the Company recorded a gain of $275 related to the $338 distribution from the sale of the Eviosys equity method investment by KPS Capital Partners. The tax charge of $64 is included in U.S. taxes on foreign income, net of credits, as a portion of the distribution was taxable in the U.S. The distribution was non-taxable in Switzerland, and is shown as a reduction of taxes on foreign income above.
Income taxes paid, net of refunds, in 2025 by jurisdiction were as follows:
| | | | | |
| 2025 |
| U.S. federal | $ | 30 | |
| U.S. state | 5 | |
| Foreign | 251 | |
| Total taxes paid, net of refunds | $ | 286 | |
The Company paid $80, $39, and $17 in Mexico, Brazil and Vietnam, respectively, in 2025, included in foreign taxes paid above. The Company paid taxes of $398 and $262, respectively, in 2024, and 2023.
The components of deferred taxes at December 31 were: | | | | | | | | | | | | | | | | | | | | | | | |
| | 2025 | | 2024 |
| | Assets | | Liabilities | | Assets | | Liabilities |
| Tax carryforwards | $ | 256 | | | $ | — | | | $ | 251 | | | $ | — | |
| Disallowed interest carryforwards | 92 | | | — | | | 105 | | | — | |
| Intangible assets | — | | | 257 | | | — | | | 260 | |
| Property, plant, and equipment | 15 | | | 290 | | | 14 | | | 257 | |
| Accruals and other | 180 | | | 79 | | | 126 | | | 129 | |
| Pensions | 51 | | | 17 | | | 48 | | | 21 | |
| Asbestos | 44 | | | — | | | 46 | | | — | |
| Postretirement and postemployment benefits | 22 | | | — | | | 23 | | | — | |
| Lease liabilities | 30 | | | — | | | 32 | | | — | |
| Right of use assets | — | | | 28 | | | — | | | 30 | |
| Valuation allowances | (185) | | | — | | | (152) | | | — | |
| Total | $ | 505 | | | $ | 671 | | | $ | 493 | | | $ | 697 | |
Tax carryforwards expire as follows:
| | | | | | | | |
| Year | | Amount |
| 2026 | | $ | 10 | |
| 2027 | | 7 | |
| 2028 | | 2 | |
| 2029 | | 4 | |
| 2030 | | 8 | |
| Thereafter | | 74 | |
| Unlimited | | 151 | |
Tax carryforwards expiring after 2030 include $46 of U.S. state tax loss carryforwards. The unlimited category includes $97 of French tax loss carryforwards and $27 of Luxembourg tax loss carryforwards. In addition, the Company has disallowed interest in the U.S. which can be carried forward indefinitely.
The Company’s valuation allowances at December 31, 2025 include $63 related to the portion of U.S. state tax loss carryforwards that the Company does not believe are more likely than not to be utilized prior to their expiration. The Company’s ability to utilize state tax loss carryforwards is impacted by several factors including taxable income, expiration dates, limitations imposed by certain states on the amount of loss carryforwards that can be used in a given year to offset taxable income and whether the state permits the Company to file a combined return. In addition, the Company’s valuation allowances at December 31, 2025 includes $88 related to tax loss carryforwards in France.
Management’s estimate of the appropriate valuation allowance in any jurisdiction involves a number of assumptions and judgments, including the amount and timing of future taxable income. Should future results differ from management’s estimates, it is possible there could be future adjustments to the valuation allowances that would result in an increase or decrease in tax expense in the period such changes in estimates are made.
A reconciliation of unrecognized tax benefits follows:
| | | | | | | | | | | | | | | | | |
| 2025 | | 2024 | | 2023 |
| Balance at January 1 | $ | 46 | | | $ | 46 | | | $ | 46 | |
| Additions for prior year tax positions | 6 | | | 10 | | | 6 | |
| Reductions to prior period tax positions | (8) | | | (4) | | | — | |
| Lapse of statute of limitations | — | | | (4) | | | (4) | |
| Settlements | (7) | | | (2) | | | (2) | |
| Foreign currency translation | 2 | | | — | | | — | |
| Balance at December 31 | $ | 39 | | | $ | 46 | | | $ | 46 | |
The Company’s unrecognized tax benefits include potential liabilities related to transfer pricing, foreign withholding taxes, and non-deductibility of expenses.
The total interest and penalties recorded in income tax expense was $2 in 2024 and 2023. As of December 31, 2025, unrecognized tax benefits of $39, if recognized, would affect the Company’s effective tax rate.
The tax years that remained subject to examination by major tax jurisdictions as of December 31, 2025 were, 2010 and subsequent years for Germany; 2011 and subsequent years for Slovakia; 2013 and subsequent years for India; 2016 and subsequent years for Thailand and Vietnam; 2017 and subsequent years for Cambodia; 2019 and subsequent years for Luxembourg; 2020 and subsequent years for Mexico, Greece, and Italy; 2021 and subsequent years for Canada, Brazil, Spain, Singapore, and Turkey; 2022 and subsequent years for the U.S. and Switzerland; 2023 and subsequent years for France and Belgium; 2024 and subsequent years for the U.K. and Netherlands. In addition, tax authorities in certain jurisdictions, including France and the U.S., may examine earlier years when tax carryforwards that were generated in those years are subsequently utilized.