Income Taxes
Income tax expense (benefit) attributable to continuing operations for the years ended December 31, 2025, 2024 and 2023, consists of the following (in millions):
 202520242023
Current provision (benefit):   
Federal$138 $357 $235 
State41 103 96 
Foreign141 109 96 
Total current provision$320 $569 $427 
Deferred provision (benefit):   
Federal$(23)$(183)$(193)
State(41)(73)
Foreign(40)17 (4)
Total deferred provision(55)(207)(270)
Total provision for income taxes$265 $362 $157 

The provision for income taxes is based on pre-tax income from continuing operations, which is as follows for the years ended December 31, 2025, 2024 and 2023 (in millions):
 202520242023
United States$864 $920 $330 
Foreign312 377 332 
Total$1,176 $1,297 $662 

Total income tax expense (benefit) attributable to continuing and discontinued operations for the years ended December 31, 2025, 2024 and 2023, is allocated as follows (in millions):
 202520242023
Tax expense (benefit) per statements of earnings (loss)$265 $362 $157 
Tax expense (benefit) on income from discontinued operations— (1,062)(301)
Change in fair value of net investment hedges(168)91 (176)
Foreign currency translation adjustments— — 40 
Share of equity method investment49 (11)— 
Other components of other comprehensive earnings (loss)(28)20 
Total income tax expense (benefit) allocated to other comprehensive earnings(147)88 (116)
Total income tax expense (benefit)$118 $(612)$(260)
A reconciliation of the federal statutory income tax rate to the Company's effective income tax rate for the years ended December 31, 2025, 2024 and 2023, after the adoption of ASU 2023-09, is as follows:
202520242023
 AmountPercentAmountPercent
Amount
Percent
U.S. Federal statutory tax rate
$247 21.0 %$272 21.0 %$139 21.0 %
State and local income taxes, net of federal income tax effect (a)
39 3.3 48 3.7 28 4.2 
Foreign tax effects
India
Withholding tax
12 1.0 24 1.8 16 2.4 
Other0.3 0.3 0.2 
Hong Kong
Nontaxable interest— — (10)(0.8)(10)(1.5)
Other— — (3)(0.2)(3)(0.4)
Bermuda
Statutory rate difference between Bermuda and U.S.
(13)(1.1)— — — — 
Other foreign jurisdictions26 2.2 38 2.9 22 3.3 
Effect of cross-border tax laws
Global intangible low-taxed income18 1.5 14 1.1 1.1 
Foreign-derived intangible income
(28)(2.4)(30)(2.3)(30)(4.5)
Other
14 1.2 0.3 — — 
Tax credits
Research and development credits(15)(1.2)(15)(1.2)(12)(1.8)
Foreign tax credits
(39)(3.3)— — — — 
Other— — — — (7)(1.1)
Changes in valuation allowances
0.5 — — — — 
Nontaxable or nondeductible items
Tax loss (benefit) from stock-based compensation
17 1.4 15 1.2 16 2.4 
Other0.1 0.1 0.2 
Changes in unrecognized tax benefits
10 0.9 (3)(0.2)(1)(0.2)
Other adjustments
Return to provision
(17)(1.4)— — (14)(2.1)
Changes in capital losses
(15)(1.3)— — — — 
Other(2)(0.2)0.2 0.6 
Effective income tax rate$265 22.5 %$362 27.9 %$157 23.8 %
(a)The jurisdictions that make up the majority (greater than 50%) of the tax effect in this category include New York City, New Jersey, California, and Florida for 2025; Florida, New York, California, Illinois, and New York City for 2024; and Florida, California, New York, Illinois, and New York City for 2023.
The significant components of deferred income tax assets and liabilities as of December 31, 2025 and 2024, consist of the following (in millions):
 20252024
Deferred income tax assets:  
Net operating loss carryforwards$490 $364 
Capital loss carryforwards136 220 
Employee benefit accruals97 115 
Equity method investment
363 — 
Other deferred tax assets292 170 
Total gross deferred income tax assets1,378 869 
Less valuation allowance(914)(505)
Total deferred income tax assets464 364 
Deferred income tax liabilities:  
Equity method investment(498)(15)
Amortization of goodwill and intangible assets(695)(707)
Deferred contract costs(298)(259)
Other deferred tax liabilities(161)(232)
Total deferred income tax liabilities(1,652)(1,213)
Net deferred income tax liability$(1,188)$(849)

Deferred income taxes are classified in the consolidated balance sheets as of December 31, 2025 and 2024, as follows (in millions):
 20252024
Noncurrent deferred income tax assets (included in Other noncurrent assets)$27 $14 
Noncurrent deferred income tax liabilities(1,215)(863)
Net deferred income tax liability$(1,188)$(849)

We believe that based on our historical pattern of taxable income, projections of future income, tax planning strategies as necessary and other relevant evidence, the Company will produce sufficient income in the future to realize its deferred income tax assets (net of valuation allowance). A valuation allowance is established for any portion of a deferred income tax asset for which we believe it is more likely than not that the Company will not be able to realize the benefits of all or a portion of that deferred income tax asset. We also receive periodic assessments from taxing authorities challenging our positions; these assessments must be taken into consideration in determining our tax accruals. Resolving these assessments, which may or may not result in additional taxes due, may require an extended period of time. Adjustments to the valuation allowance will be made if there is a change in our assessment of the amount of deferred income tax asset that is realizable.

As of December 31, 2025 and 2024, the Company had net income taxes receivable of $325 million and a net income taxes payable of $236 million, respectively. As of December 31, 2025, $325 million of income tax receivable was included in Other receivables in the consolidated balance sheet. As of December 31, 2024, $279 million of income tax payable was included in Accounts payable, accrued and other liabilities and $43 million of income tax receivable was included in Other receivables in the consolidated balance sheet.

As of December 31, 2025 and 2024, the Company had federal, state and foreign NOL carryforwards that resulted in deferred tax assets of $490 million and $364 million, respectively. Of these amounts, $143 million and $70 million, respectively, relate to federal and state NOL carryforwards. Most federal and state NOL carryforwards expire between 2026 and 2043, while a small number do not expire. The Company recorded valuation allowances of $55 million and $47 million as of December 31, 2025 and 2024, respectively, related to deferred tax assets arising from federal and state NOL carryforwards. Foreign NOL carryforwards resulted in deferred tax assets of $347 million and $294 million as of December 31, 2025 and 2024, respectively, and the Company maintained a valuation allowance against substantially all deferred tax assets arising from foreign NOL carryforwards as of both reporting dates.
As of December 31, 2024, as a result of the 2024 Worldpay Sale, the Company recorded a deferred tax asset of $220 million related to the U.S. capital loss recognized in the transaction, offset by a valuation allowance of $130 million. As of December 31, 2025, the Company maintained a deferred tax asset of $136 million related to the U.S. capital loss, fully offset by a valuation allowance of $136 million. The $84 million decrease in this deferred tax asset is primarily attributable to the carryback of the loss against available capital gains.

As of December 31, 2024, as a result of the 2024 Worldpay Sale, the Company recognized a $15 million deferred tax liability for the difference between the tax basis of the Worldpay equity method investment and the corresponding financial statement carrying value. During 2025, as a result of the 2026 Worldpay Minority Interest Sale, the Company remeasured the existing deferred tax liability to account for the change in our intent to hold the investment for the long term, as well as our best estimate of the ordinary versus capital characterization of the expected proceeds. In accordance with the provisions of ASC 740, the net deferred tax liability recognized in connection with our Worldpay equity method investment reflects the difference between the tax basis of the investment and the corresponding financial statement carrying value. As of December 31, 2025, the Company maintained a $498 million deferred tax liability and a $363 million deferred tax asset, fully offset by a valuation allowance, related to the equity method investment in Worldpay. As discussed in Note 1, the 2026 Worldpay Minority Interest Sale was completed on January 9, 2026, and the tax due will be based on the excess of sales proceeds over the tax basis and a number of other factors, including the valuation of assets held in Worldpay, how the form of the transaction was effectuated and the final purchase price allocation. The continued assessment of these factors and their potential impact on the ordinary versus capital characterization of the expected proceeds could result in a material change to the realizability of the deferred tax assets for U.S. capital loss carryforwards and the final tax computed on the sale.

The Company participates in the IRS' Compliance Assurance Process ("CAP"), which is a real-time continuous audit. The IRS has completed its review for years through 2021. Currently, we believe the ultimate resolution of the IRS examinations will not result in a material adverse effect to the Company's financial position or results of operations. Tax years that remain subject to examination by major foreign and state tax jurisdictions are 2017 and forward.

As of December 31, 2025 and 2024, the Company had gross unrecognized tax benefits of $60 million and $49 million of which $51 million and $41 million, respectively, would favorably impact our income tax rate in the event that the unrecognized tax benefits are recognized.

The following table reconciles the gross amounts of unrecognized tax benefits at the beginning and end of the period (in millions):
 Gross Amount
Unrecognized tax benefits as of December 31, 2023
$41 
Decreases due to lapse of the applicable statute of limitations(6)
Increases due to settlements
Increases as a result of tax positions taken in the prior period
Increases as a result of tax positions taken in the current period
Unrecognized tax benefit as of December 31, 2024
49 
Decreases due to lapse of the applicable statute of limitations(1)
Decreases due to settlements(2)
Decreases as a result of tax positions taken in prior period(13)
Increases as a result of tax positions taken in the current period27 
Unrecognized tax benefit as of December 31, 2025
$60 

The total amount of interest expense recognized in the consolidated statements of earnings (loss) for unpaid taxes is $2 million, $3 million and $2 million for the years ended December 31, 2025, 2024 and 2023, respectively. The total amount of interest and penalties included in the consolidated balance sheets is $12 million and $10 million as of December 31, 2025 and 2024, respectively. Interest and penalties are recorded as a component of income tax expense in the consolidated statements of earnings (loss).
The following table summarizes the cash payments for income taxes for the period ended December 31, 2025, 2024, and 2023 as follows (in millions):
202520242023
Federal
$395 $288 $159 
State
60 90 85 
Foreign
United Kingdom
44 35 52 
Other foreign jurisdictions
129 75 106 
Total
$628 $488 $402 

Historical Timeline

Fiscal YearFiled
2025Feb 24, 2026Showing above
2024Feb 13, 2025
2023Feb 26, 2024
2022Feb 27, 2023
2021Feb 23, 2022
2020Feb 18, 2021
2019Feb 20, 2020
2018Feb 21, 2019
2017Feb 22, 2018
2016Feb 23, 2017
2015Feb 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.