(15) Income Taxes

 

The sources of income before income taxes for the years ended December 31, 2025, 2024 and 2023 are presented as follows:

 

 

 

Year Ended December 31,

(in millions)

 

 

2025

 

 

2024

 

 

2023

Income before taxes:

 

 

 

 

 

 

 

 

 

United States

 

$

(100.4)

 

$

(29.7)

 

$

7.0

Foreign

 

 

548.6

 

 

478.6

 

 

393.4

Total income before income taxes

 

$

448.2

 

$

448.9

 

$

400.4

 

The Company's income tax expense for the years ended December 31, 2025, 2024 and 2023 consisted of the following:

 

 

 

Year Ended December 31,

(in millions)

 

 

2025

 

 

2024

 

 

2023

Current tax expense (benefit):

 

 

 

 

 

 

 

 

 

U.S. Federal

 

$

0.6

 

$

1.9

 

$

2.8

U.S. state and local

 

 

13.3

 

 

2.4

 

 

2.3

Foreign

 

 

143.3

 

 

118.6

 

 

102.9

Total current

 

 

157.2

 

 

122.9

 

 

108.0

Deferred tax expense (benefit):

 

 

 

 

 

 

 

 

 

U.S. Federal

 

 

(13.9)

 

 

4.5

 

 

10.4

U.S. state and local

 

 

(10.0)

 

 

1.6

 

 

1.8

Foreign

 

 

1.9

 

 

13.6

 

 

0.7

Total deferred

 

 

(22.0)

 

 

19.7

 

 

12.9

Total tax expense

 

$

135.2

 

$

142.6

 

$

120.9

 

Beginning in 2025 annual reporting, we adopted ASU 2023-09 prospectively. See Note 3 – Summary of Significant Accounting Policies –Recently Adopted Accounting Pronouncements for additional details on the adoption of ASU 2023-09. A reconciliation of the U.S. federal statutory income tax rate to our effective tax rate pursuant to the disclosure requirements of ASU 2023-09 for the year ended December 31, 2025 is as follows (in millions, except for percentages):

 

 

 

Year Ended December 31, 2025

 

U.S. Federal income tax expense (benefit) at applicable statutory rate:

 

$

94.1

 

 

21.00

%

Effects of cross border tax laws

 

 

(0.8)

 

 

(0.18)

 

Changes in valuation allowance

 

 

13.2

 

 

2.95

 

Nontaxable and nondeductible items

 

 

 

 

 

 

 

Stock compensation

 

 

5.90

 

 

1.31

 

State and local income taxes, net of federal effect

 

 

0.40

 

 

0.10

 

Other

 

 

2.80

 

 

0.60

 

Foreign

 

 

 

 

 

 

 

Germany

 

 

 

 

 

 

 

State and local income taxes

 

 

12.1

 

 

2.69

 

Other

 

 

(5.5)

 

 

(1.24)

 

Netherlands

 

 

 

 

 

 

 

Nontaxable and nondeductible items

 

 

 

 

 

 

 

Loss on corporate reorganization

 

 

(28.3)

 

 

(6.31)

 

Withholding tax

 

 

5.4

 

 

1.21

 

Other

 

 

(3.7)

 

 

(0.81)

 

United Kingdom

 

 

 

 

 

 

 

Nontaxable and nondeductible items

 

 

 

 

 

 

 

Gain on corporate reorganization

 

 

29.5

 

 

6.59

 

Other

 

 

4.6

 

 

1.03

 

Other foreign jurisdictions

 

 

16.9

 

 

3.78

 

Changes in unrecognized tax benefits

 

 

(11.4)

 

 

(2.55)

 

Total

 

$

135.2

 

 

30.17

%

 

The following is a reconciliation of the federal statutory income tax rates of 21% to the effective income tax rate for the years ended December 31, 2024, and 2023:

 

 

 

Year Ended December 31,

 

(dollar amounts in millions)

 

 

2024

 

 

2023

 

U.S. federal income tax expense at applicable statutory rate

 

$

94.3

 

$

84.1

 

Tax effect of:

 

 

 

 

 

 

 

State income tax expense at statutory rates, net of U.S. federal income tax

 

 

3.5

 

 

3.7

 

Non-deductible expenses

 

 

4.1

 

 

2.9

 

Share-based compensation

 

 

3.9

 

 

4.0

 

Other permanent differences

 

 

8.0

 

 

0.9

 

Difference between U.S. federal and foreign tax rates

 

 

21.8

 

 

16.7

 

Provision in excess of statutory rates

 

 

(0.5)

 

 

8.3

 

Change in federal and foreign valuation allowance

 

 

1.2

 

 

2.7

 

GILTI, net of tax credits

 

 

12.9

 

 

5.9

 

Tax credits

 

 

(6.0)

 

 

(9.2)

 

Other

 

 

(0.6)

 

 

0.9

 

Total income tax expense

 

$

142.6

 

$

120.9

 

Effective tax rate

 

 

31.77

%

 

30.19

%

 

We calculate our provision for federal, state and foreign income taxes based on current tax law.

 

Cash paid for income taxes, net of refunds received, by jurisdiction pursuant to the disclosure requirement of ASU 2023-09 for the year ended December 31, 2025 is as follows (in millions):

 

(in millions)

 

 

Year Ended December 31, 2025

Federal

 

$

(10.1)

State

 

 

14.4

Foreign

 

 

 

Germany

 

 

37.2

Greece

 

 

10.3

India

 

 

16.2

Italy

 

 

9.6

Spain

 

 

18.8

United Kingdom

 

 

9.3

Other

 

 

47.0

Total cash paid for income taxes, net of refunds received

 

$

152.7

 

The tax effect of temporary differences and carryforwards that give rise to deferred tax assets and liabilities from continuing operations are as follows:

 

 

 

As of December 31,

(in millions)

 

 

2025

 

 

2024

Deferred tax assets:

 

 

 

 

 

 

Tax loss carryforwards

 

$

45.4

 

$

44.8

Share-based compensation

 

 

17.6

 

 

15.0

Accrued expenses

 

 

21.3

 

 

19.3

Property and equipment

 

 

10.2

 

 

6.8

Goodwill and intangible amortization

 

 

10.7

 

 

9.3

Contract costs

 

 

 

 

0.7

Intercompany notes

 

 

5.6

 

 

6.6

Accrued revenue

 

 

1.1

 

 

0.7

Tax credits

 

 

45.5

 

 

61.6

Lease accounting

 

 

38.4

 

 

34.3

Foreign exchange

 

 

13.0

 

 

8.8

Capitalized research and development

 

 

22.3

 

 

10.8

Capped call premium

 

 

24.1

 

 

Other

 

 

3.8

 

 

6.3

Total deferred tax assets

 

 

259.0

 

 

225.0

Valuation allowance

 

 

(87.9)

 

 

(75.0)

Total deferred tax assets, net of valuation allowance

 

 

171.1

 

 

150.0

Deferred tax liabilities:

 

 

 

 

 

 

Intangible assets related to purchase accounting

 

 

(56.9)

 

 

(28.2)

Goodwill and intangible amortization

 

 

(32.2)

 

 

(31.8)

Accrued expenses

 

 

(16.4)

 

 

(15.3)

Intercompany notes

 

 

(5.9)

 

 

(5.8)

Accrued interest

 

 

(3.2)

 

 

(42.6)

Property and equipment

 

 

(8.9)

 

 

(6.9)

Accrued revenue

 

 

(1.7)

 

 

(1.7)

Lease accounting

 

 

(38.4)

 

 

(34.3)

Foreign exchange

 

 

(1.0)

 

 

(14.7)

Partnership Investment

 

 

(13.0)

 

 

(7.6)

Deferred revenue

 

 

(7.6)

 

 

(6.7)

Other

 

 

(2.3)

 

 

(0.9)

Total deferred tax liabilities

 

 

(187.5)

 

 

(196.5)

Net deferred tax liabilities

 

$

(16.4)

 

$

(46.5)

 

Net deferred tax assets of $61.9 million and $25.3 million as of December 31, 2025 and 2024, respectively, are recorded within "Other assets" on the Consolidated Balance Sheet.

 

Subsequently recognized tax benefits relating to the valuation allowance for deferred tax assets as of December 31, 2025 are expected to be allocated to income taxes in the Consolidated Statements of Operations. As of December 31, 2025 and 2024, the Company's foreign tax loss carryforwards were $193.8 million and $183.3 million, respectively, and U.S. state tax loss carryforwards were $58.2 million and $81.0 million, respectively.

 

As of December 31, 2025 and 2024, the Company has U.S. foreign tax credit carryforwards of $43.6 million and $57.1 million respectively, which are largely not expected to be utilized in future periods.

 

In assessing the Company's ability to realize deferred tax assets, management considers whether it is more likely than not that some portion or all of the deferred tax assets will not be realized. The ultimate realization of deferred tax assets is dependent upon the generation of future taxable income during the periods in which those temporary differences become deductible. Management considers the scheduled reversal of deferred tax liabilities, projected future taxable income and tax planning strategies in making this assessment. Based upon the level of historical taxable income and projections for future taxable income over the periods in which the deferred tax assets are deductible, management believes it is more likely than not the Company will realize the benefits of these deductible differences, net of the existing valuation allowances, as of December 31, 2025.

 

As of December 31, 2025, the Company had foreign tax net operating loss carryforwards of $193.8 million, which will expire as follows:

 

(in millions)

 

Gross

 

Tax Effected

Year ending December 31,

 

 

 

 

 

 

2026

 

$

2.9

 

$

0.7

2027

 

 

2.6

 

 

0.6

2028

 

 

4.1

 

 

1.0

2029

 

 

5.5

 

 

1.2

2030

 

 

22.1

 

 

4.6

Thereafter

 

 

6.8

 

 

1.7

Unlimited

 

 

149.8

 

 

31.9

Total

 

$

193.8

 

$

41.7

 

In addition, the Company's state tax net operating loss carryforwards of $58.2 million will expire periodically from 2026 through 2044, U.S. foreign tax credit carryforwards of $43.6 million will expire periodically from 2027 through 2034 and U.S. federal research and expenditure credit carryforwards of $1.9 million will expire periodically from 2034 through 2044.

 

The Company has not provided additional deferred taxes with respect to items such as certain foreign exchange gains or losses, foreign withholding taxes or additional state taxes, if any, on undistributed earnings attributable to foreign subsidiaries and it is not practical to determine the income tax liability that would be payable if such earnings were not reinvested indefinitely. Gross undistributed earnings reinvested indefinitely in foreign subsidiaries aggregated approximately $2,987.3 million as of December 31, 2025.

 

Based upon the current Organization for Economic Co-operation and Development (OECD) rules and administrative guidance, as well as the related legislation of those countries which has been enacted to date, the Company does not anticipate being subject to material minimum foreign taxes. The Company is continuing to monitor the potential impact of the Pillar Two proposals for a minimum effective tax rate and related developments on our Consolidated Financial Statements and related disclosures, including eligibility for any transitional safe harbor rules.

 

Accounting for uncertainty in income taxes

 

A reconciliation of the beginning and ending amount of unrecognized tax benefits for the years ended December 31, 2025 and 2024 is as follows:

 

 

 

Year Ended December 31,

(in millions)

 

 

2025

 

 

2024

Beginning balance

 

$

48.6

 

$

51.8

Additions based on tax positions related to the current year

 

 

7.1

 

 

6.2

Additions for tax positions of prior years

 

 

4.2

 

 

1.4

Reductions for tax positions of prior years

 

 

(0.1)

 

 

(4.0)

Settlements

 

 

(12.3)

 

 

(0.2)

Statute of limitations expiration

 

 

(6.1)

 

 

(6.6)

Ending balance

 

$

41.4

 

$

48.6

 

As of December 31, 2025 and 2024, approximately $41.2 million and $36.4 million, respectively, of the unrecognized tax benefits would impact the Company's provision for income taxes and effective income tax rate, if recognized. Total estimated accrued interest and penalties related to the underpayment of income taxes was $7.0 million and $7.1 million as of December 31, 2025 and 2024, respectively.

 

The Company is subject to taxation in the U.S. and various state and foreign jurisdictions.  The major jurisdictions which remain subject to examination after 2014 include the U.S., Germany, India, and Spain.

 

It is reasonably possible that the balance of gross unrecognized tax benefits could significantly change within the next twelve months as a result of the resolution of audit examinations and expirations of certain statutes of limitations and, accordingly, materially affect the Company's operating results. At this time, it is not possible to estimate the range of change due to the uncertainty of potential outcomes.

Historical Timeline

Fiscal YearFiled
2025Feb 26, 2026Showing above
2024Feb 25, 2025
2023Feb 22, 2024
2022Feb 22, 2023
2021Feb 23, 2022
2020Feb 22, 2021
2019Mar 2, 2020
2018Feb 28, 2019
2017Mar 1, 2018
2016Mar 1, 2017
2015Feb 29, 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.