Note 13. Income Taxes

Although the Company is a Delaware limited partnership, we are subject to corporate income tax on our share of the Partnership’s earnings because of our election to be treated as a corporation for U.S. federal and state income tax purposes. The provision for income taxes consisted of:

 

 

 

Year Ended December 31,

 

(in millions)

 

2025

 

 

2024

 

 

2023

 

Federal

 

 

 

 

 

 

 

 

 

Current

 

$

0.2

 

 

$

0.2

 

 

$

0.1

 

Deferred taxes and other accruals

 

 

93.6

 

 

 

59.1

 

 

 

31.2

 

State

 

 

20.0

 

 

 

12.5

 

 

 

6.6

 

Total provision for income taxes

 

$

113.8

 

 

$

71.8

 

 

$

37.9

 

The reconciliation between the U.S. statutory federal income tax rate and the Company’s effective income tax rate for the year ended December 31, 2025, in accordance with ASU 2023-09 guidance is as follows:

 

 

Year Ended December 31, 2025

 

 

Amount

 

 

Percent

U.S. statutory rate

 

$

167.7

 

 

 

21.0

 

%

Noncontrolling interest in partnership

 

 

(69.6

)

 

 

(8.7

)

 

State income taxes, net of federal income tax(1)

 

 

15.7

 

 

 

2.0

 

 

Effective rate

 

$

113.8

 

 

 

14.3

 

%

(1) State taxes in North Dakota made up the majority (greater than 50%) of the tax effect in this category.

The reconciliation between the U.S. statutory federal income tax rate and the Company’s effective income tax rate for the years ended December 31, 2024 and 2023, as previously reported, is as follows:

 

 

Year Ended December 31,

 

 

2024

 

2023

U.S. statutory rate

 

 

21.0

 

%

 

 

21.0

 

%

Noncontrolling interest in partnership

 

 

(12.5

)

 

 

 

(15.9

)

 

State income taxes, net of federal income tax

 

 

1.4

 

 

 

 

0.8

 

 

Effective rate

 

 

9.9

 

%

 

 

5.9

 

%

 

As a result of the equity offering and unit repurchase transactions (see Note 3, Equity Transactions), we recognized an additional deferred tax asset in the total amount of $305.0 million (2024: $329.8 million) related to the change in the temporary difference between the carrying amount and the tax basis of our investment in the Partnership. The effect of recognizing the additional deferred tax asset was included in Class A shareholders’ equity balance in the accompanying consolidated statement of changes in partners’ capital due to the transactions being characterized as transactions among or with shareholders.

The components of deferred tax assets and liabilities are as follows:

 

 

 

December 31,

 

 

 

2025

 

 

2024

 

(in millions)

 

 

 

 

 

 

Deferred tax liabilities

 

 

 

 

 

 

Investments

 

$

(0.5

)

 

$

(0.5

)

Total deferred tax liabilities

 

 

(0.5

)

 

 

(0.5

)

Deferred tax assets

 

 

 

 

 

 

Investments

 

 

650.3

 

 

 

514.5

 

Net operating loss carryforwards

 

 

123.6

 

 

 

68.1

 

Total deferred tax assets

 

 

773.9

 

 

 

582.6

 

Net deferred tax assets (liabilities)

 

$

773.4

 

 

$

582.1

 

 

At December 31, 2025, we have recognized a deferred tax asset of $102.5 million related to U.S. federal net operating loss carryforwards which do not expire and $21.1 million related to U.S. state net operating loss carryforwards which begin to expire in 2029. We have no unrecognized tax benefits or interest and penalties related to tax liabilities recorded in the financial statements. For the years presented, we earned all net income before taxes in the United States. We file income tax returns in the U.S. and various states. During the years presented, we did not have any material federal or state income tax payments. We are not subject to corporate income tax examination for years prior to 2022.

Historical Timeline

Fiscal YearFiled
2025Feb 25, 2026Showing above
2024Feb 27, 2025
2023Feb 29, 2024
2022Feb 27, 2023
2021Mar 1, 2022
2020Feb 23, 2021
2019Feb 21, 2020

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.