Income Taxes
On July 4, 2025, the One Big Beautiful Bill Act (the "OBBBA") was enacted in the United States, which extended and modified certain provisions of the 2017 Tax Cuts and Jobs Act (the "TCJA"). The provisions of the OBBBA did not have any impact on the Company's operating results, financial position or cash flows for the twelve months ended December 31, 2025, and is not expected to have a material impact on future periods.

Noncurrent income taxes payable— On December 22, 2017, the TCJA was enacted in the United States. The provisions of the TCJA significantly revised the U.S. corporate income tax rules. In connection with the enactment of the TCJA, the Company recorded a one-time additional income tax expense of $676 million in the fourth quarter of 2017 related to a one-time repatriation tax on the deemed repatriation of post-1986 undistributed earnings of foreign subsidiaries. A portion of the resulting income taxes payable could be paid in installments over eight years. The final installment of the noncurrent income taxes payable related to the one-time repatriation tax of $151 million was reported in Income taxes payable as of December 31, 2024, and paid when due during the twelve months ended December 31, 2025.

Provision for income taxes— The components of the provision for income taxes for the twelve months ended December 31, 2025, 2024 and 2023 were as follows:

In millions202520242023
U.S. federal income taxes:
Current$418 $486 $455 
Deferred(25)(576)(111)
Total U.S. federal income taxes393 (90)344 
Foreign income taxes:
Current413 515 405 
Deferred487 31 
Total foreign income taxes418 1,002 436 
State income taxes:
Current86 109 94 
Deferred(87)(8)
Total state income taxes89 22 86 
Total provision for income taxes$900 $934 $866 

Income before taxes for domestic and foreign operations for the twelve months ended December 31, 2025, 2024 and 2023 was as follows:

In millions202520242023
Domestic$2,384 $2,603 $1,953 
Foreign1,582 1,819 1,870 
Total income before taxes$3,966 $4,422 $3,823 
Effective with the Company's annual disclosures for the year ended December 31, 2025, the Company prospectively adopted new guidance which requires disclosure of specific categories and greater disaggregation of information presented in the effective tax rate reconciliation. The following table is a reconciliation between the U.S. federal statutory tax rate and the effective tax rate for the twelve months ended December 31, 2025:

2025
Dollars in millionsIncome TaxesTax Rate
U.S. federal statutory tax rate$833 21.0 %
State income taxes, net of U.S. federal tax benefit70 1.8 
Foreign tax effects82 2.1 
Effect of cross-border tax laws:
Foreign-derived deduction eligible income(45)(1.1)
Other(34)(0.9)
Tax credits(12)(0.3)
Change in valuation allowances
(6)(0.2)
Nontaxable or nondeductible items(2)— 
Changes in unrecognized tax benefits13 0.3 
Other— 
Effective tax rate$900 22.7 %

State income taxes in California, Illinois, Pennsylvania, Minnesota, and Florida made up the majority of State income taxes, net of U.S. federal tax benefit for the twelve months ended December 31, 2025.

The following table is a reconciliation between the U.S. federal statutory rate and the effective tax rate for the twelve months ended December 31, 2024 and 2023:

20242023
U.S. federal statutory tax rate21.0 %21.0 %
State income taxes, net of U.S. federal tax benefit2.0 1.8 
Differences between U.S. federal statutory and foreign tax rates1.0 1.1 
U.S. tax effect of foreign earnings0.5 0.8 
Remeasurement of unrecognized tax benefit1.6 0.6 
Change in valuation allowances(2.3)0.5 
Intellectual property reorganization(1.1)— 
Audit resolution0.1 (0.2)
Excess tax benefits from stock-based compensation (0.3)(0.5)
Foreign-derived intangible income
(1.2)(1.4)
Other, net(0.2)(1.1)
Effective tax rate21.1 %22.6 %

The Company's effective tax rate for the twelve months ended December 31, 2025, 2024 and 2023 was 22.7%, 21.1% and 22.6%, respectively. The 2025 effective tax rate included a discrete tax benefit of $21 million in the first quarter of 2025 related to the reversal of a valuation allowance on net operating loss carryforwards. Additionally, the 2025 effective tax rate benefited from a discrete tax benefit in the third quarter of 2025 of $43 million related to the estimated U.S. federal tax liability for 2024, partially offset by a $16 million discrete tax expense related primarily to the resolution of a foreign tax audit. The 2024 effective tax rate benefited from discrete income tax benefits during the third quarter of 2024 of $107 million related to the utilization of capital loss carryforwards upon the sale of Wilsonart and $87 million related to a reorganization of the Company's intellectual property, partially offset by a $73 million discrete tax expense related to the remeasurement of unrecognized tax benefits associated with various intercompany transactions. The 2023 effective tax rate benefited from a discrete income tax benefit of $20 million in the second quarter of 2023 related to amended 2021 U.S. taxes. Additionally, the effective tax rates for 2025, 2024 and 2023 included discrete income tax benefits of $8 million, $14 million, and $20 million, respectively, related to excess tax benefits from stock-based compensation.
Upon repatriation of foreign earnings to the U.S., the Company may be subject to foreign withholding taxes. The accrual for foreign withholding taxes related to the expected repatriation of foreign held cash and equivalents as of December 31, 2025 and 2024 was $47 million and $44 million, respectively.

Deferred foreign withholding taxes have not been provided on undistributed earnings considered permanently invested. As of December 31, 2025, undistributed earnings of certain international subsidiaries that are considered permanently invested were approximately $6 billion. Determination of the related deferred tax liability is not practicable because of the complexities associated with the hypothetical calculation.

Deferred tax assets and liabilities— The components of deferred income tax assets and liabilities as of December 31, 2025 and 2024 were as follows:

 20252024
In millionsAssetLiabilityAssetLiability 
Goodwill and intangible assets$511 $(491)$553 $(476)
Inventory reserves and capitalized tax cost54 — 54 — 
Investments19 (56)24 (53)
Plant and equipment23 (112)19 (108)
Accrued expenses and reserves32 — 35 — 
Employee benefit accruals129 — 137 — 
Foreign tax credit carryforwards15 — 13 — 
Net operating loss carryforwards494 — 465 — 
Capital loss carryforwards78 — 81 — 
Allowances for uncollectible accounts12 — 11 — 
Capitalized research and development225 — 173 — 
Pension liabilities— (60)— (43)
Unrealized loss (gain) on foreign debt instruments43 — — (98)
Operating leases62 (62)56 (56)
Other37 (53)32 (53)
Gross deferred income tax assets (liabilities)1,734 (834)1,653 (887)
Valuation allowances(535)— (516)— 
Total deferred income tax assets (liabilities)$1,199 $(834)$1,137 $(887)

The valuation allowances recorded as of December 31, 2025 and 2024 related primarily to certain net operating loss carryforwards and capital loss carryforwards. As of December 31, 2025, the Company had utilized all realizable foreign tax credit carryforwards.
As of December 31, 2025, the Company had net operating loss carryforwards available to offset future taxable income in the U.S. and certain foreign jurisdictions, which expire as follows:

Gross
In millionsCarryforwards
2026$
2027— 
2028
2029
2030— 
2031— 
2032-2050899 
Do not expire992 
Total gross carryforwards related to net operating losses$1,896 

Cash paid for income taxes, net of refunds— Effective with the Company's annual disclosures for the year ended December 31, 2025, the Company prospectively adopted new guidance which requires disaggregation of income taxes paid by jurisdiction. The following table presents income taxes paid by jurisdiction, net of refunds, for the twelve months ended December 31, 2025:

In millions2025
U.S. federal$516 
State78 
Foreign458 
Total cash paid for income taxes, net of refunds$1,052 

Jurisdictions representing greater than 5% of total cash paid for income taxes, net of refunds, for the twelve months ended December 31, 2025 included China and Germany, which were $92 million and $74 million, respectively.

Unrecognized tax benefits— The changes in the amount of unrecognized tax benefits for the twelve months ended December 31, 2025, 2024 and 2023 were as follows:

In millions202520242023
Beginning balance$359 $329 $314 
Additions based on tax positions related to the current year35 21 
Additions for tax positions of prior years27 37 48 
Reductions for tax positions of prior years(18)(30)(33)
Settlements(82)— (23)
Foreign currency translation17 (12)
Ending balance$310 $359 $329 

Included in the balance as of December 31, 2025 were approximately $281 million of unrecognized tax benefits that, if recognized, would impact the Company's effective tax rate.

The Company and its subsidiaries file tax returns in the U.S. and various state, local and foreign jurisdictions. These tax returns are routinely audited by the tax authorities in these jurisdictions including the Internal Revenue Service, His Majesty's Revenue and Customs, German Fiscal Authority, French Fiscal Authority, and Australian Tax Office, and a number of these audits are currently ongoing, which may increase the amount of the unrecognized tax benefits in future periods.
The following table summarizes the open tax years for the Company's major jurisdictions:

JurisdictionOpen Tax Years
United States – Federal
2019-2025
United Kingdom
2017-2025
Germany
2019-2025
France
2023-2025
Australia
2015-2025

The Company recognizes interest and penalties related to income tax matters in income tax expense. The accrual for interest and penalties as of December 31, 2025 and 2024 was $75 million and $69 million, respectively.

Historical Timeline

Fiscal YearFiled
2025Feb 13, 2026Showing above
2024Feb 14, 2025
2023Feb 9, 2024
2022Feb 10, 2023
2021Feb 11, 2022
2020Feb 12, 2021
2019Feb 14, 2020
2018Feb 15, 2019
2017Feb 15, 2018
2016Feb 10, 2017
2015Feb 12, 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.