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Income (Loss) Before Income Taxes | | | | | |
| Year ended December 31 (in millions) | 2025 | | 2024 | | 2023 |
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| Domestic | $ | 26,766 | | | $ | 19,615 | | | $ | 22,164 | |
| Foreign | (1,000) | | | (942) | | | (1,686) | |
| $ | 25,766 | | | $ | 18,673 | | | $ | 20,478 | |
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Components of Income Tax Expense | | | | | |
| Year ended December 31 (in millions) | 2025 | | 2024 | | 2023 |
| Current Expense (Benefit): | | | | | |
| Federal | $ | 2,286 | | | $ | 2,194 | | | $ | 6,270 | |
| State | 720 | | | 1,115 | | | 1,591 | |
| Foreign | 427 | | | 389 | | | 249 | |
| 3,432 | | | 3,698 | | | 8,110 | |
| Deferred Expense (Benefit): | | | | | |
| Federal | 2,420 | | | (599) | | | (2,126) | |
| State | 539 | | | (49) | | | (468) | |
| Foreign | (285) | | | (253) | | | (145) | |
| 2,674 | | | (902) | | | (2,739) | |
| Income tax expense (benefit) | $ | 6,106 | | | $ | 2,796 | | | $ | 5,371 | |
Our income tax expense (benefit) differs from the federal statutory amount because of the effect of the items detailed in the table below.
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| 2025 | | 2024 | | 2023 |
| Year ended December 31 (in millions) | Amount | % | | Amount | % | | Amount | % |
| Federal tax at statutory rate | $ | 5,411 | | 21.0 | % | | $ | 3,921 | | 21.0 | % | | $ | 4,300 | | 21.0 | % |
State and local income tax, net of federal income tax effect(a) | 710 | | 2.8 | % | | 338 | | 1.8 | % | | 426 | | 2.1 | % |
| Foreign tax effects | 353 | | 1.4 | % | | 364 | | 2.0 | % | | 461 | | 2.3 | % |
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| Effect of cross-border tax laws | (81) | | (0.3) | % | | (95) | | (0.5) | % | | (88) | | (0.4) | % |
| Tax credits | (280) | | (1.1) | % | | (328) | | (1.8) | % | | (280) | | (1.4) | % |
| Nontaxable or nondeductible items | 141 | | 0.6 | % | | 55 | | 0.3 | % | | 90 | | 0.4 | % |
| Changes in unrecognized tax benefits | 281 | | 1.1 | % | | 476 | | 2.6 | % | | 459 | | 2.2 | % |
| Other | | | | | | | | |
| Internal corporate reorganization | (174) | | (0.7) | % | | (1,920) | | (10.3) | % | | — | | — | % |
| Other adjustments | (254) | | (1.0) | % | | (16) | | (0.1) | % | | 3 | | — | % |
| Effective tax rate | $ | 6,106 | | 23.7 | % | | $ | 2,796 | | 15.0 | % | | $ | 5,371 | | 26.2 | % |
(a) The majority of the tax effect in this category was attributable to state taxes in Illinois, Florida, New Jersey, New York and Pennsylvania in 2025; California, Illinois and New Jersey in 2024; and California, Illinois, Massachusetts, New Jersey and New York in 2023.
We base our provision for income taxes on our current period income, changes in our deferred income tax assets and liabilities, income tax rates, changes in estimates of our uncertain tax positions, tax planning opportunities available in the jurisdictions in which we operate and excess tax benefits or deficiencies that arise when the tax consequences of share-based compensation differ from amounts previously recognized in the statements of income. We recognize deferred tax assets and liabilities when there are temporary differences between the financial reporting basis and tax basis of our assets and liabilities and for the expected benefits of using net operating loss carryforwards. When a change in the tax rate or tax law has an impact on deferred taxes, we apply the change based on the years in which the temporary differences are expected to reverse. We record the change in our consolidated financial statements in the period of enactment.
The determination of the income tax consequences of a business combination includes identifying the tax basis of assets and liabilities acquired and any contingencies associated with uncertain tax positions assumed or resulting from the business combination. Deferred tax assets and liabilities related to temporary differences of an acquired entity are recorded as of the date of the business combination and are based on our estimate of the ultimate tax basis that will be accepted by the various tax authorities. We record liabilities for contingencies associated with prior tax returns filed by the acquired entity based on criteria set forth in the appropriate accounting guidance. We adjust the deferred tax accounts and the liabilities periodically to reflect any revised estimated tax basis and any estimated settlements with the various tax authorities. The effects of these adjustments are recorded to income tax expense.
From time to time, we engage in transactions in which the tax consequences may be subject to uncertainty. In these cases, we evaluate our tax position using the recognition threshold and the measurement attribute in accordance with the accounting guidance related to uncertain tax positions. Examples of these transactions include business acquisitions and dispositions, including consideration paid or received in connection with these transactions, certain financing transactions, and the allocation of income among state and local tax jurisdictions. Significant judgment is required in assessing and estimating the tax consequences of these transactions. We determine whether it is more likely than not that a tax position will be sustained on examination, including the resolution of any related appeals or litigation processes, based on the technical merits of the position. A tax position that meets the more-likely-than-not recognition threshold is measured to determine the amount of benefit to be recognized in our consolidated financial statements. We classify interest and penalties, if any, associated with our uncertain tax positions as a component of income tax expense (benefit).
Impact of Federal Legislation
In 2025, legislation was signed into law in the United States that, among other things, provided for immediate deduction of 100% of the costs of qualified property, including significant portions of our capital expenditures and film and television production costs, acquired and placed into service after January 19, 2025, compared to the 40% and 20% deductions that would have applied in 2025 and 2026, respectively, under prior law. The legislation also reinstated the immediate deduction of domestic research and development expenses, retroactive to 2022, repealing the prior requirement to capitalize and amortize such costs over five years. The legislation resulted in a reduction of our income taxes payable of $1.4 billion and a corresponding increase of our net deferred tax liability. There is no material impact to our income tax expense or effective tax rate.
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Components of Net Deferred Tax Liability | | | |
| December 31 (in millions) | 2025 | | 2024 |
| Deferred Tax Assets: | | | |
Net operating loss and other loss carryforwards(a) | $ | 5,278 | | | $ | 4,415 | |
Advance on sale of investment (see Note 8) | — | | | 2,437 | |
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| Nondeductible accruals and other | 4,493 | | | 4,232 | |
Less: Valuation allowance(a) | 5,271 | | | 4,498 | |
| | 4,500 | | | 6,586 | |
| Deferred Tax Liabilities: | | | |
| Property and equipment and intangible assets | 29,561 | | | 28,590 | |
| Investments | 563 | | | 934 | |
| Debt | 1,880 | | | 2,055 | |
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| Other | 147 | | | 125 | |
| 32,152 | | | 31,704 | |
| Net deferred tax liability | $ | 27,652 | | | $ | 25,118 | |
(a)Includes net operating loss and other loss carryforwards of $2.1 billion related to assets classified as held for sale as of December 31, 2025, for which a full valuation allowance is recognized.
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Changes in our Valuation Allowance for Deferred Tax Assets | | | | | |
| (in millions) | 2025 | | 2024 | | 2023 |
| Beginning balance | $ | 4,498 | | | $ | 3,679 | | | $ | 3,295 | |
| Additions charged to income tax expense and other accounts | 848 | | | 910 | | | 469 | |
| Deductions from reserves | (75) | | | (91) | | | (84) | |
| Ending balance | $ | 5,271 | | | $ | 4,498 | | | $ | 3,679 | |
Changes in our net deferred tax liability in 2025 that were not recorded as deferred income tax expense (benefit) are primarily related to a decrease of $121 million associated with items included in other comprehensive income (loss).
As of December 31, 2025, net operating loss and other carryforwards primarily reflects foreign net operating loss carryforwards of $14.0 billion, which primarily relate to our foreign operations in Europe and the majority of which can be carried forward indefinitely. The determination of the realization of the foreign net operating loss carryforwards is dependent on our subsidiaries’ taxable income or loss, redetermination from taxing authorities, and foreign laws that can change from year to year and impact the amount of such carryforwards. We recognize a valuation allowance if we determine it is more likely than not that some portion, or all, of a deferred tax asset will not be realized. As of December 31, 2025 and 2024, our valuation allowance was primarily related to our foreign net operating loss carryforwards.
During 2024, we completed an internal corporate reorganization related to certain foreign subsidiaries, which resulted in a federal net capital loss of $9.1 billion as of December 31, 2024. This capital loss could be carried back and applied against capital gains recognized on our prior federal income tax returns for 2021 through 2023, and as a result, we recognized an income tax benefit and a corresponding refund receivable of $1.9 billion in 2024. In 2025, we received the federal income tax refund as a result of carrying back this capital loss. Deferred federal income tax has not been recognized on the excess of the financial reporting basis over the tax basis in foreign subsidiaries resulting from the reorganization where indefinite reversal criteria have been met. Any liabilities would be recognized upon a taxable disposition of such subsidiaries; however, the determination of the amount of any unrecognized deferred income tax liabilities is not practicable.
Net current federal tax receivables of $2.0 billion were included in other current assets within our consolidated balance sheet as of December 31, 2024. There were no net current federal tax receivables as of December 31, 2025.
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Cash Payments for Income Taxes | | | |
| Year ended December 31 (in millions) | 2025 | 2024 | 2023 |
Federal(a)(b) | $ | (89) | | $ | 6,011 | | $ | 4,208 | |
| State | 380 | | 742 | | 596 | |
Foreign(c) | 464 | | 342 | | 302 | |
| Cash payments for income taxes | $ | 755 | | $ | 7,096 | | $ | 5,107 | |
(a)Includes $0.6 billion and $1.7 billion for 2025 and 2024, respectively, related to the purchase of third-party transferable tax credits.
(b)Changes in other operating assets and liabilities in the consolidated statements of cash flows included a decrease in current tax receivables for the year ended in December 31, 2025, an increase in current tax receivables and a decrease in current taxes payable for the year ended December 31, 2024, and an increase in current taxes payable for the year ended December 31, 2023.
(c)The year ended December 31, 2025 includes payments of $229 million for Japan.
Uncertain Tax Positions
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Reconciliation of Unrecognized Tax Benefits | | | | | |
(in millions) | 2025 | | 2024 | | 2023 |
| Gross unrecognized tax benefits, January 1 | $ | 2,865 | | | $ | 2,593 | | | $ | 2,161 | |
| Additions based on tax positions related to the current year | 297 | | | 396 | | | 546 | |
| Additions based on tax positions related to prior years | 9 | | | 201 | | | 1 | |
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| Reductions for tax positions of prior years | (95) | | | (268) | | | (43) | |
| Reductions due to expiration of statutes of limitations | (94) | | | (29) | | | (56) | |
| Settlements with tax authorities and other | (55) | | | (28) | | | (15) | |
| Gross unrecognized tax benefits, December 31 | $ | 2,927 | | | $ | 2,865 | | | $ | 2,593 | |
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Our gross unrecognized tax benefits include both amounts related to positions for which we have recorded liabilities for potential payment obligations and those for which tax has been assessed and paid. The amounts exclude the federal benefits on state tax positions that were recorded to deferred income taxes. If we were to recognize our gross unrecognized tax benefits in the future, $2.3 billion would impact our effective tax rate and the remaining amount would increase our deferred income tax liability. The amount and timing of the recognition of any such tax benefit is dependent on the completion of examinations of our tax filings by the various tax authorities and the expiration of statutes of limitations. Accrued interest and penalties associated with our liability for uncertain tax positions were not material in any period presented.
The IRS has completed its examination of our income tax returns for all years through 2022. Various states are examining our state tax returns and the tax years of those tax returns currently under examination vary by state, with most of the periods relating to tax years 2011 and forward. Various foreign jurisdictions are examining our tax returns and the tax years of those tax returns currently under examination vary by country, with most of the periods relating to tax years 2017 and forward.