8.     INCOME TAXES
Our provision for income taxes consisted of the following:
Year Ended December 31,
(in millions)202520242023
U.S. federal:
Current$37.6 34.1 88.1 
Deferred(12.1)(22.7)(160.1)
$25.5 11.4 (72.0)
State and Local:
Current$17.8 12.8 33.4 
Deferred(1.7)(5.7)(54.6)
$16.1 7.1 (21.2)
International:
Current$197.1 120.7 161.2 
Deferred(49.2)(6.7)(42.3)
$147.9 114.0 118.9 
Total$189.5 132.5 25.7 
The U.S. Internal Revenue Code contains two taxes, the Base Erosion Anti-Abuse Tax and Global Intangible Low-Taxed Income Tax, for which we treat any associated income tax as a period cost and record an expense provision for any year we are subject to the taxes. Accordingly, the estimated impacts of these taxes were included in our provision for income taxes for all periods presented.
Due to the generation of net operating loss carryovers, our current tax expense increased by $13.8 million, $36.0 million and $69.1 million in 2025, 2024 and 2023, respectively, and our deferred tax expense was reduced by a corresponding amount.
We adopted ASU 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures, prospectively. As such, we have included the required expanded disclosures for the year ended December 31, 2025, while disclosures for the years ended December 31, 2024 and 2023 reflect the previous disclosure requirements.
Income tax expense differed from the amounts computed by applying the U.S. federal income tax rate of 21% to earnings before provision for income taxes as a result of the following:
Year Ended December 31,
($ in millions)2025
Computed "expected" tax expense$206.1 21.0 %
State and local income tax, net of federal (national) income tax effect(1)
12.9 1.3 
Foreign tax effects
Singapore
Unremitted income(11.7)(1.2)
Other(4.8)(0.5)
Other countries21.0 2.2 
Effect of cross-border tax laws
U.S. global intangible low-taxed income (GILTI)15.0 1.5 
Other(2.6)(0.3)
Changes in valuation allowances(2.6)(0.3)
Nontaxable or nondeductible items
Nontaxable deferred compensation insurance trust earnings(17.9)(1.8)
Nondeductible executive compensation10.6 1.1 
Effect of legal entity restructuring(17.1)(1.7)
Other(8.4)(0.9)
Changes in unrecognized tax benefits(9.9)(1.0)
Other, net(1.1)(0.1)
Grand Total $189.5 19.3 %
(1) State and local income taxes in California, the District of Columbia, Illinois, New York and New York City comprise the majority of the state and local income taxes, net of federal effect category.
On July 4, 2025, the United States enacted the One Big Beautiful Bill Act (“OBBBA”). The OBBBA includes provisions
altering the timing of deduction from certain depreciable assets, research and experimental expenses, and interest expense,
with some effective in 2025 and some in 2026. The current period’s financial statements include the impact of the OBBBA
provisions effective for 2025, which are primarily in the nature of timing differences which do not impact this year's effective tax rate. The OBBBA further alters the determination and rates of taxation of international earnings, effective in 2026. We are still evaluating these provisions, which may decrease overall U.S. tax on international subsidiary income.
Year Ended December 31,
($ in millions)20242023
Income tax expense at statutory rates$142.6 21.0 %$52.9 21.0 %
Increase (reduction) in income taxes from:
State and local income taxes, net of federal income tax benefit5.4 0.8 (17.1)(6.8)
Nondeductible expenses13.8 2.0 7.1 2.9 
International earnings taxed at various rates(32.3)(4.8)(58.4)(23.2)
Valuation allowance12.7 1.9 41.3 16.4 
Other, net(9.7)(1.4)(0.1)(0.1)
Total$132.5 19.5 %$25.7 10.2 %
With respect to international earnings taxed at varying rates, we have operations which constitute a taxable income presence in over 93 countries or other taxable jurisdictions outside of the U.S. which are treated as such by the U.S. Internal Revenue Code. Of those countries or other taxable jurisdictions, 70 had income tax rates lower than the combined U.S. federal and state income tax rate in 2025, of which some are very low tax rate jurisdictions, with combined national and municipal state or provincial rates of 25% or lower. While the U.S. federal income tax rate is 21%, after factoring in the impact of state income taxes, we do not consider the U.S. to be a very low tax rate jurisdiction. With respect to very low tax rate jurisdictions in which we operate, income from Hong Kong (16.5%) and Singapore (17%) represent the most significant components of the international earnings line item in our effective tax rate reconciliation for 2024 and 2023.
Our income (loss) before taxes from domestic (U.S.) and international sources is presented in the following table.
Year Ended December 31,
(in millions)202520242023
Domestic$249.7 93.4 (175.5)
International732.0 585.9 427.4 
Total$981.7 679.3 251.9 
The tax effects of temporary differences that give rise to significant portions of the deferred tax assets and deferred tax liabilities are presented below.
December 31,
(in millions)20252024
Deferred tax assets attributable to:
Accrued expenses$533.7 472.3 
U.S. federal and state loss and credit carryovers72.4 66.2 
Allowances for uncollectible accounts37.0 37.5 
International loss carryovers361.1 330.6 
Investments24.8 20.4 
Pension liabilities30.7 27.9 
Other3.6 — 
Deferred tax assets1,063.3 954.9 
Less: valuation allowances(198.2)(164.9)
Net deferred tax assets$865.1 790.0 
Deferred tax liabilities attributable to:
Intangible assets297.7 277.5 
Income deferred for tax purposes13.4 26.6 
Other 13.3 
Deferred tax liabilities$311.1 317.4 
Net deferred taxes$554.0 472.6 
The increase in gross deferred tax assets in 2025 was primarily the result of accrued expenses. The increase in valuation allowances was primarily the result of additional losses incurred in countries with existing valuation allowances.
We have not provided a deferred tax liability on the unremitted foreign earnings of international subsidiaries because it is our intent to permanently reinvest such earnings outside of the U.S. If repatriation of all such earnings were to occur, we would incur withholding taxes, dividend distribution taxes and potentially an amount of gain taxation which is not presently determinable.
As of December 31, 2025, we had an available U.S. federal net operating loss ("NOL") carryover of $78.1 million from acquired companies, for which we have established a full valuation allowance due to significant statutory limitations on its usage, and which will begin to expire in 2032. We have U.S. state NOL carryovers with a tax effect of $24.1 million, which expire at various dates through 2045, and international NOL carryovers of $1,449.8 million, which generally do not have expiration dates. The change in deferred tax balances for NOL carryovers from 2024 to 2025 included increases from current year losses and decreases from current year estimated utilization.
As of December 31, 2025, we believe it is more-likely-than-not the net deferred tax assets of $554.0 million will be realized based upon our estimates of future taxable income and the consideration of net operating losses, earnings trends and tax planning strategies. Valuation allowances have been provided with regard to the tax benefit of certain international NOL carryovers, for which we have concluded recognition is not yet appropriate. In 2025, we reduced valuation allowances by $9.9 million on some jurisdictions' NOLs due to the utilization or expiration of those losses; and we increased valuation allowances by $37.0 million for other jurisdictions based upon circumstances that caused us to establish or continue to provide valuation allowances on current or prior-year losses (including acquired NOL carryovers) in addition to those provided in prior years. The remaining movement in valuation allowances comparing December 31, 2025 to December 31, 2024 was attributable to the effect of changes in foreign currency exchange rates.
The following table presents net current and net non-current payable for income tax.
December 31,
(in millions)20252024
Current payable for income tax
Current payable$305.6 286.2 
Current receivable(198.1)(218.2)
Net current payable for income tax $107.5 68.0 
Non-current payable for income tax
Non-current payable$50.4 62.2 
Non-current receivable — 
Net non-current payable for income tax $50.4 62.2 
The current receivables, current payables, and noncurrent payables are included in Notes and other receivables, Accounts payable and accrued liabilities, and Other liabilities, respectively, on our Consolidated Balance Sheets.
We file income tax returns in the U.S. (including 46 states, 25 cities, the District of Columbia and Puerto Rico), the United Kingdom (including England, Scotland and Wales), Australia, Germany, The People's Republic of China (including Hong Kong and Macau), France, Japan, Singapore, India, the Netherlands, Spain and approximately 78 other countries. Generally, our open tax years include those from 2022 to the present, although reviews of taxing authorities for more recent years have been completed or are in process in a number of jurisdictions.
As of December 31, 2025, we were under examination in Belgium, Germany, Egypt, Indonesia, India, Mauritius, Pakistan, the Philippines, Poland, Portugal, Sri Lanka, Switzerland, Thailand, the U.S. and Vietnam. Also in the U.S., we were under examination in the states of Texas and Wisconsin.
A reconciliation of the beginning and ending amount of unrecognized tax benefits is presented in the following table.
(in millions)20252024
Balance as of January 1,
$73.7 71.2 
Additions based on tax positions related to the current year1.5 2.8 
(Decrease) increase related to tax positions of prior years(11.5)1.6 
Settlements with taxing authorities (1.9)
Balance as of December 31,
$63.7 73.7 
The recognition of tax benefits, and other changes to the amounts of our unrecognized tax benefits, may occur as the result of ongoing operations, the outcomes of audits or other examinations by tax authorities, or the passing of statutes of limitations. We do not expect changes to our unrecognized tax benefits to have a significant impact on our net income, financial position, or cash flows. We do not believe we have material tax positions for which the ultimate deductibility is highly certain but there is uncertainty about the timing of such deductibility.
We recognize interest accrued and penalties, if any, in Income tax provision on our Consolidated Statements of Comprehensive Income. During the years ended December 31, 2025, 2024 and 2023, the amount of interest expense and penalties was not material. In addition, the amount of accrued interest related to income taxes was not material as of December 31, 2025 and 2024.
The following table presents income taxes paid (net of refunds received) to federal, state and foreign taxing authorities, including individual jurisdictions where taxes paid (net of refunds received) exceeded 5% of total taxes paid (net of refunds received).
Year Ended December 31,
(in millions)2025
Federal$53.4 
State15.1 
Foreign
Australia17.4 
Canada12.9 
England26.2 
Japan23.5 
All other77.5 
Total Foreign 157.5 
Total$226.0 

Historical Timeline

Fiscal YearFiled
2025Feb 19, 2026Showing above
2024Feb 19, 2025

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.