INCOME TAXES
The components of net (loss) income before income taxes are as follows (in thousands):
| | | | | | | | | | | | | | | | | |
| Year Ended December 31, |
| 2025 | | 2024 | | 2023 |
| United States | $ | (221,935) | | | $ | 20,850 | | | $ | (67,496) | |
| Foreign | 59,628 | | | 66,105 | | | 40,591 | |
| Net (loss) income before income taxes | $ | (162,307) | | | $ | 86,955 | | | $ | (26,905) | |
The components of income tax expense (benefit) are as follows (in thousands):
| | | | | | | | | | | | | | | | | |
| Year Ended December 31, |
| 2025 | | 2024 | | 2023 |
| Current: | | | | | |
| United States | $ | 26,327 | | | $ | 22,965 | | | $ | 26,720 | |
| Foreign | 19,401 | | | 17,611 | | | 1,823 | |
| Total current income tax expense (benefit) | 45,728 | | | 40,576 | | | 28,543 | |
| Deferred: | | | | | |
| United States | (8,877) | | | 3,943 | | | (15,169) | |
| Foreign | 7,025 | | | 2,964 | | | (59,856) | |
| Total deferred income tax expense (benefit) | (1,852) | | | 6,907 | | | (75,025) | |
| Total provision for income tax expense | $ | 43,876 | | | $ | 47,483 | | | $ | (46,482) | |
Upon adoption of ASU 2023-09, the income taxes paid, net of refunds, during the year ended December 31, 2025 are as follows (in thousands): | | | | | |
| Year Ended December 31, |
| 2025 |
| United States - Federal | $ | 18,065 | |
| United States - State and Local | 5,299 | |
| Foreign | |
| Australia | 3,760 | |
| Canada | 4,211 | |
| Japan | 2,462 | |
| United Kingdom | 2,580 | |
| Other | 7,916 | |
| Total income taxes paid, net of refunds | $ | 44,293 | |
Income taxes paid, net of refunds, during the years ended December 31, 2024 and 2023 was $41.4 million and $31.7 million, respectively. Due to prospective adoption of ASU 2023-09, the income taxes paid for years ended December 31, 2024 and 2023 are not presented on a disaggregated basis.
Upon adoption of ASU 2023-09, the Company is required to present additional disaggregated information within the effective tax rate reconciliation. The following table reflects the items accounting for the difference between income taxes computed at the U.S. federal statutory rate and the effective income tax rate for the year ended December 31, 2025, in accordance with the disclosure requirements of ASU 2023-09 (in thousands):
| | | | | | | | | | | |
| Year Ended December 31, |
| 2025 |
| U.S. federal tax at statutory rate | $ | (34,085) | | | 21.0 | % |
State and local income taxes, net of federal income tax effect1 | 6,486 | | | (4.0) | % |
| Foreign tax effects: | | | |
| Ireland | | | |
| Foreign jurisdiction rate differential | (4,370) | | | 2.7 | % |
| Other | 495 | | | (0.3) | % |
| Luxembourg | | | |
| Nontaxable foreign exchange loss (gain) | 2,589 | | | (1.6) | % |
| Nondeductible interest expense | 2,650 | | | (1.6) | % |
| Other | (620) | | | 0.4 | % |
| Canada | | | |
| Nondeductible dividend income | (5,245) | | | 3.2 | % |
| Changes in valuation allowances | 2,223 | | | (1.4) | % |
| Other | 1,147 | | | (0.7) | % |
| Australia | | | |
| Withholding taxes | 2,945 | | | (1.8) | % |
| Other | 291 | | | (0.2) | % |
| Japan | | | |
| Withholding taxes | 2,161 | | | (1.3) | % |
| Other foreign jurisdictions | | | |
| Other | 7,255 | | | (4.5) | % |
| Effect of changes in tax laws or rates enacted in the current period | — | | | — | % |
| Effect of cross-border tax laws: | | | |
| Global intangible low-taxed income | 3,899 | | | (2.4) | % |
| Other | (1,116) | | | 0.7 | % |
| Tax credits: | | | |
| Research and development tax credits | (530) | | | 0.3 | % |
| Foreign tax credits | 22,483 | | | (13.9) | % |
| | | |
| Changes in valuation allowances | 31,879 | | | (19.6) | % |
| Nontaxable or nondeductible items: | | | |
| Stock-based compensation | 2,474 | | | (1.4) | % |
| Tax impact on interest rate swap instrument | 1,947 | | | (1.2) | % |
| Other | 457 | | | (0.3) | % |
| Changes in unrecognized tax benefits | (1,539) | | | 0.9 | % |
| Effective tax rate | $ | 43,876 | | | (27.0) | % |
1The jurisdictions that contribute to the majority of the tax effect in this category include New York and New York City.
As the Company adopted ASU 2023-09 on a prospective basis effective January 1, 2025, the enhanced disaggregation requirements do not apply to the comparative periods. Therefore, the rate reconciliations for the years
ended December 31, 2024 and 2023 are presented in accordance with the guidance in effect prior to the adoption of ASU 2023-09 (in thousands):
| | | | | | | | | | | |
| Year Ended December 31, |
| 2024 | | 2023 |
| Federal income tax expense (benefit) at the statutory rate | $ | 18,274 | | | $ | (5,651) | |
| Effect of: | | | |
| State taxes, net of federal benefit | 3,369 | | | (1,736) | |
| Tax impact of foreign earnings and losses | 16,440 | | | 11,524 | |
| Stock-based compensation | 2,657 | | | 3,633 | |
| | | |
| Valuation allowance | (3,656) | | | (49,425) | |
| Tax credits | 11,449 | | | (5,284) | |
| Other, net | (1,050) | | | 457 | |
| Income tax expense (benefit) | $ | 47,483 | | | $ | (46,482) | |
Uncertain Tax Positions
The Company follows the provisions of accounting for uncertainty in income taxes. This guidance clarifies the accounting for uncertainty in income taxes recognized in the consolidated financial statements and prescribes a recognition threshold of more likely than not and a measurement attribute on all tax positions taken or expected to be taken in a tax return for their recognition in the financial statements.
A reconciliation of the beginning and ending amounts of unrecognized tax benefits is as follows (in thousands):
| | | | | | | | | | | | | | | | | |
| Year Ended December 31, |
| 2025 | | 2024 | | 2023 |
| Uncertain tax benefits, beginning of year | $ | 16,416 | | | $ | 20,155 | | | $ | 28,967 | |
| Gross increase to tax positions related to prior years | 391 | | | — | | | 338 | |
| Gross decrease to tax positions related to prior years | (210) | | | (1,457) | | | (36) | |
| Gross increase to tax positions related to the current year | 309 | | | 2,953 | | | 2,036 | |
| Gross decrease to tax positions related to the current year | — | | | — | | | — | |
| Settlements | — | | | — | | | (4,636) | |
| Lapse of statute of limitations | (2,361) | | | (5,235) | | | (6,514) | |
| Uncertain tax benefits, end of year | $ | 14,545 | | | $ | 16,416 | | | $ | 20,155 | |
As of December 31, 2025, the Company had $14.5 million of gross unrecognized tax benefits, of which $14.5 million, if fully recognized, would affect the Company’s effective tax rate. The timing of resolution for these liabilities is uncertain. The resolution of these items may result in additional or reduced income tax expense. Possible releases of liabilities due to expirations of statutes of limitations will have the effect of decreasing the Company’s income tax expense and the effective tax rate, if and when they occur.
The Company recognizes interest and penalties related to liabilities for uncertain tax positions in income tax expense in the Consolidated Statements of Operations. Interest and penalties were $0.7 million, $(2.2) million, and $(3.5) million for the years ended December 31, 2025, 2024, and 2023, respectively. The Company has recognized total accrued interest and penalties of approximately $7.4 million, $6.7 million, and $8.9 million as of December 31, 2025, 2024, and 2023, respectively, relating to uncertain tax positions.
The Company conducts business globally and, as a result, the Company and its subsidiaries file income tax returns in the U.S., including various states, and foreign jurisdictions. In the normal course of business, the Company is subject to examination by taxing authorities throughout the world. The tax years 2022 and forward are open for U.S. federal income tax matters. The tax years 2018 and forward are open for U.S. state income tax matters. With few exceptions, foreign tax filings are open for years 2012 and subsequent years. As of December 31, 2025, the Company
is currently undergoing audit examinations for tax years 2018 through 2021 by the New York State Department of Taxation, for tax years 2014 through 2016 by the Canada Revenue Agency, and for tax years 2015 through 2021 by the Ireland Tax Appeals Commission.
Deferred Taxes and Valuation Allowances
The Company follows authoritative guidance for accounting for income taxes, which requires the Company to reduce deferred tax by a valuation allowance if, based on the weight of all available positive and negative evidence, it is more likely than not that some portion or all of the deferred tax assets will not be realized. After consideration of all available evidence for the realizability of U.S. deferred tax assets, the Company provided a valuation allowance of $194.5 million and $145.9 million for the years ended December 31, 2025 and December 31, 2024, respectively. In future periods, the Company will evaluate the positive and negative evidence available at the time in order to support its analysis for a valuation allowance, and as a result the Company may release its valuation allowance in part, or in total, when it becomes more likely than not that the deferred tax assets will be realized.
Deferred tax assets, liabilities and valuation allowance are as follows (in thousands):
| | | | | | | | | | | |
| December 31, |
| 2025 | | 2024 |
| Deferred tax assets | | | |
| Income tax attributes | $ | 237,791 | | | $ | 240,182 | |
| Accrued liabilities and reserves | 70,487 | | | 27,600 | |
| Operating lease liabilities | 4,841 | | | 7,060 | |
| Prepaid expenses | 395 | | | — | |
| Unrealized foreign exchange gains/losses | 16,972 | | | — | |
| Stock-based compensation expense | 5,364 | | | 5,388 | |
| Other | 2,126 | | | 1,003 | |
| Gross deferred tax assets | 337,976 | | | 281,233 | |
| Less valuation allowance | (215,425) | | | (164,322) | |
| Total deferred tax assets | 122,551 | | | 116,911 | |
| Deferred tax liabilities | | | |
| Amortization and depreciation | (73,810) | | | (53,012) | |
| Operating lease assets | (3,935) | | | (5,707) | |
| Prepaid expenses | — | | | (2,738) | |
| Unrealized foreign exchange gains/losses | — | | | (14,949) | |
| Other | (1,046) | | | (897) | |
| Net deferred tax assets, net of valuation allowance | $ | 43,760 | | | $ | 39,608 | |
The deferred tax assets at December 31, 2025, with respect to net operating loss carryforwards and expiration periods are as follows (in thousands):
| | | | | | | | | | | |
| Deferred Tax Assets | | Net Operating Loss Carryforwards |
| United States, expiring between 2026 and 2043 | $ | 8,483 | | | $ | 120,660 | |
| Foreign, expiring between 2025 and 2045 | 16,624 | | | 68,994 | |
| Foreign, indefinite | 57,818 | | | 449,089 | |
| Total | $ | 82,925 | | | $ | 638,743 | |
The following is information pertaining to U.S. federal tax credits at December 31, 2025, as well as the expiration periods (in thousands):
| | | | | |
| Tax Credits |
| United States, federal tax credit carryforwards: | |
| Foreign tax credits, expiring between 2031 and 2034 | $ | 3,937 | |
| Total | $ | 3,937 | |
The components of our net deferred taxes at the reported balance sheet dates are primarily comprised of amounts relating to net operating loss carryforwards, accrued assets and liabilities, and depreciable and amortizable assets.