13. Income Taxes

The 2025 loss from continuing operations before income tax benefit from U.S. operations is $111 million.

Reconciliations of the statutory U.S. federal income tax rates to our effective tax rate for continuing operations follow:

 

 

Years Ended December 31,

 

 

 

2024

 

 

2023

 

Statutory federal rate

 

 

21.0

%

 

 

21.0

%

Non-deductible goodwill impairment

 

 

4.2

 

 

 

 

Non-deductible regulatory-related expenses

 

 

2.4

 

 

 

 

Recognition of deferred tax asset on government
   services business basis difference

 

 

(5.3

)

 

 

 

State tax, net of federal income tax effect

 

 

4.2

 

 

 

5.5

 

Other, net

 

 

(1.5

)

 

 

.6

 

Effective tax rate

 

 

25.0

%

 

 

27.1

%

 

 

 

Year Ended December 31, 2025

 

(Dollars in millions)

 

Amount

 

 

Percent

 

Statutory federal rate

 

$

(23

)

 

 

21.0

%

Federal

 

 

 

 

 

 

   Tax credits

 

 

 

 

 

 

     Energy-related tax credits

 

 

(2

)

 

 

1.6

 

     Other

 

 

(1

)

 

 

.5

 

   Nontaxable or nondeductible items

 

 

 

 

 

 

     Executive compensation

 

 

2

 

 

 

(1.6

)

     Market value adjustments on life insurance contracts

 

 

(2

)

 

 

2.1

 

     Other

 

 

 

 

 

(.2

)

   Other adjustments

 

 

(1

)

 

 

.8

 

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

 

 

(6

)

 

 

5.6

 

Changes in unrecognized tax benefits

 

 

2

 

 

 

(1.7

)

Total tax (benefit) / expense and effective rate

 

$

(31

)

 

 

28.1

%

 

(1)
In 2025, state taxes in Virginia, California and Delaware comprise the majority of the state income taxes, net of federal income tax effect category.

 

 

13. Income Taxes (Continued)

Income tax expense (benefit) consists of:

 

 

 

December 31,

 

(Dollars in millions)

 

2025

 

 

2024

 

 

2023

 

Current provision/(benefit):

 

 

 

 

 

 

 

 

 

Federal

 

$

(28

)

 

$

29

 

 

$

63

 

State

 

 

(5

)

 

 

8

 

 

 

24

 

Total current provision/(benefit)

 

 

(33

)

 

 

37

 

 

 

87

 

 

 

 

 

 

 

 

 

 

 

Deferred provision/(benefit):

 

 

 

 

 

 

 

 

 

Federal

 

 

2

 

 

 

5

 

 

 

 

State

 

 

 

 

 

1

 

 

 

(2

)

Total deferred provision/(benefit)

 

 

2

 

 

 

6

 

 

 

(2

)

 

 

 

 

 

 

 

 

 

 

Total provision/(benefit):

 

 

 

 

 

 

 

 

 

Federal

 

 

(26

)

 

 

34

 

 

 

63

 

State

 

 

(5

)

 

 

9

 

 

 

22

 

Provision for income tax expense/(benefit)

 

$

(31

)

 

$

43

 

 

$

85

 

 

Income taxes paid (net of refunds received) consists of:

(Dollars in millions)

 

Year Ended December 31, 2025

 

Federal

 

$

18

 

State

 

 

1

 

Income taxes paid (net of refunds received)

 

$

19

 

 

13. Income Taxes (Continued)

The tax effect of temporary differences that give rise to deferred tax assets and liabilities include the following:

 

 

December 31,

 

(Dollars in millions)

 

2025

 

 

2024

 

Deferred tax assets:

 

 

 

 

 

 

Loan reserves

 

$

164

 

 

$

181

 

Accrued expenses not currently deductible

 

 

18

 

 

 

22

 

Education loan premiums and discounts, net

 

 

40

 

 

 

40

 

Government services business held for sale

 

 

 

 

 

18

 

Operating loss and credit carryovers

 

 

84

 

 

 

9

 

Stock-based compensation plans

 

 

7

 

 

 

7

 

Acquired intangible assets

 

 

 

 

 

9

 

Other

 

 

14

 

 

 

16

 

Total deferred tax assets

 

 

327

 

 

 

302

 

Deferred tax liabilities:

 

 

 

 

 

 

Market value adjustments on education
   loans, investments and derivatives

 

 

115

 

 

 

100

 

Original issue discount on borrowings

 

 

14

 

 

 

13

 

Acquired intangible assets

 

 

9

 

 

 

 

Other

 

 

2

 

 

 

5

 

Total deferred tax liabilities

 

 

140

 

 

 

118

 

Net deferred tax assets

 

$

187

 

 

$

184

 

Included in operating loss and credit carryovers is a valuation allowance of $151 million and $123 million as of December 31, 2025 and 2024, respectively, against a portion of the Company’s state deferred tax assets. The valuation allowance is primarily attributable to deferred tax assets for state net operating loss carryovers and state IRC § 163(j) disallowed interest expense carryovers that management believes it is more likely than not will expire prior to being realized. The ultimate realization of the deferred tax assets is dependent upon the generation of future taxable income of the appropriate character (i.e., capital or ordinary) during the period in which the temporary differences become deductible. Factors generally considered by management include (but are not limited to): any changes in economic conditions, the scheduled reversals of deferred tax liabilities, and the history of positive taxable income in evaluating the realizability of the deferred tax assets.

The operating loss and credit carryovers consist of:

 

 

 

December 31, 2025

 

(Dollars in millions)

 

Gross

 

Tax-Effected

 

Expiration

Corresponding Valuation Allowance(1)

 

Operating Loss
and Credit Carryovers

 

Federal operating loss carryovers

 

$

318

 

$

66

 

Begins in 2032

$

 

$

66

 

Federal capital loss carryovers

 

 

63

 

 

13

 

Begins in 2030

 

 

 

13

 

State capital loss carryovers

 

 

63

 

 

3

 

Begins in 2030

 

1

 

 

2

 

State operating loss carryovers

 

 

990

 

 

55

 

Begins in 2026

 

52

 

 

3

 

State IRC § 163(j) disallowed
   interest expense carryovers

 

 

6,824

 

 

98

 

Indefinite

 

98

 

 

 

 

 

 

 

$

235

 

 

$

151

 

$

84

 

 

(1)
The valuation allowance attributable to deferred tax assets for state net operating loss carryovers, and state IRC § 163(j) disallowed interest expense carryovers, are amounts that management believes more likely than not will expire prior to being realized.

 

 

13. Income Taxes (Continued)

Accounting for Uncertainty in Income Taxes

The following table summarizes changes in unrecognized tax benefits:

 

 

December 31,

 

(Dollars in millions)

 

2025

 

 

2024

 

 

2023

 

Unrecognized tax benefits at beginning of year

 

$

47.1

 

 

$

48.5

 

 

$

50.7

 

Increases resulting from tax positions taken during a prior period

 

 

 

 

 

8.8

 

 

 

3.8

 

Decreases resulting from tax positions taken during a prior period

 

 

(4.0

)

 

 

(6.4

)

 

 

(4.5

)

Increases resulting from tax positions taken during the current period

 

 

7.2

 

 

 

10.2

 

 

 

7.4

 

Decreases related to settlements with taxing authorities

 

 

(.5

)

 

 

(6.0

)

 

 

(3.8

)

Increases related to settlements with taxing authorities

 

 

 

 

 

 

 

 

 

Reductions related to the lapse of statute of limitations

 

 

(2.6

)

 

 

(8.0

)

 

 

(5.1

)

Unrecognized tax benefits at end of year (1)

 

$

47.2

 

 

$

47.1

 

 

$

48.5

 

 

(1)
Included in the $47.2 million of gross unrecognized tax benefits at December 31, 2025 are $37.3 million of unrecognized tax benefits that, if recognized, would favorably impact the effective tax rate.

The Company or one of its subsidiaries files income tax returns at the U.S. federal level, in most U.S. states, and various foreign jurisdictions. All periods prior to 2022 are closed for federal examination purposes. Various combinations of subsidiaries, tax years, and jurisdictions remain open for review, subject to statute of limitations periods (typically 3 to 4 prior years). We do not expect the resolution of open audits to have a material impact on our unrecognized tax benefits.

Historical Timeline

Fiscal YearFiled
2025Feb 26, 2026Showing above
2024Feb 27, 2025
2023Feb 26, 2024
2022Feb 24, 2023
2021Feb 25, 2022
2020Feb 26, 2021
2019Feb 27, 2020
2018Feb 26, 2019
2017Feb 26, 2018
2016Feb 24, 2017
2015Feb 25, 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.