Income Taxes
Income before provision for income taxes was as follows:
For the Year Ended December 31,
(in millions)202520242023
U.S.$1,289 $696 $1,665 
Foreign1,398 1,218 1,092 
Total$2,687 $1,914 $2,757 
The provision for income taxes has the following components:
For the Year Ended December 31,
(in millions)202520242023
Current:
Federal$255 $377 $270 
State68 108 117 
Foreign240 242 193 
Total current provision$563 $727 $580 
Deferred:
Federal$10 $(199)$31 
State13 (55)
Foreign22 — (37)
Total deferred provision45 (254)(4)
Total provision for income taxes$608 $473 $576 
The following tables reconcile the provision for income taxes computed at the U.S. federal statutory tax rate to the provision for income taxes reported in the Consolidated Statements of Income:
For the Year Ended December 31, 2025
($ in millions)AmountPercentage
Statutory federal income tax rate$564 21.0 %
State income taxes, net(1)
59 2.2 
Impact of foreign operations
Ireland
Statutory tax rate difference between Ireland and U.S.(71)(2.6)
Other20 0.7 
Other foreign jurisdictions21 0.8 
Effect of cross-border tax laws9 0.3 
Tax credits(28)(1.0)
Nontaxable or nondeductible items12 0.4 
Changes in unrecognized tax benefits22 0.8 
Total provision for income taxes$608 22.6 %
(1)California, Tennessee, New Jersey, Florida, Illinois, and Texas comprise more than 50% of State income taxes, net.
For the Year Ended December 31,
20242023
Statutory federal income tax rate21.0 %21.0 %
State income taxes, net2.1 3.2 
Impact of foreign operations(1.4)(1.7)
Tax credits(6.2)(3.7)
Valuation allowance for deferred tax assets0.6 — 
U.S. taxation of foreign earnings5.1 3.0 
Goodwill impairment2.7 — 
Deferred rate change(0.4)(0.3)
Uncertain tax positions— 0.1 
U.S. federal provision to return0.2 — 
Excess tax deductions on stock-based compensation(0.2)(0.3)
Other1.2 (0.4)
Effective tax rate24.7 %20.9 %
Deferred tax assets and liabilities were comprised of the following:
 December 31,
(in millions)20252024
Deferred tax assets:
Operating lease liability$236 $229 
Net operating losses carryforwards24 30 
Tax credit carryforwards5 10 
Accrued expenses152 154 
Research and development capitalization45 94 
Accrued termination fees52 56 
Other84 107 
Total deferred tax assets598 680 
Valuation allowances(24)(25)
Total deferred tax assets, net of valuation allowances$574 $655 
Deferred tax liabilities:
Brands, trade names and other intangible assets$(5,540)$(5,486)
Property, plant, and equipment(230)(299)
Right of use assets(234)(224)
Other(60)(42)
Total deferred tax liabilities(6,064)(6,051)
Net deferred tax liabilities$(5,490)$(5,396)
CASH PAID FOR INCOME TAXES
For the year ended December 31, 2025, our cash paid for income taxes, net of refunds received, consisted of the following:
(in millions)
For the Year Ended December 31, 2025
U.S.
Federal$103 
State95 
Foreign
Mexico103 
Ireland102 
Canada31 
Other foreign jurisdictions26 
Total cash paid for income taxes, net of refunds received
$460 
We paid $331 million and $507 million in cash for income taxes, net of refunds received, during the years ended December 31, 2024 and 2023, respectively.
CARRYFORWARDS
As of December 31, 2025 and 2024, we had $24 million and $30 million, respectively, in tax-effected net operating loss carryforwards. Of the $24 million of net operating loss carryforwards as of December 31, 2025, $21 million will not expire, $1 million related to state income tax will begin to expire in 2027, and the remaining $2 million related to foreign income tax will begin to expire in the year 2035.
As of December 31, 2025 and 2024, we had $5 million and $10 million of credit carryforwards, respectively. As of December 31, 2025, the $5 million of state tax credit carryforwards will begin to expire in the year 2027.
VALUATION ALLOWANCES
For the year ended December 31, 2025, the changes in our valuation allowances were insignificant.
UNDISTRIBUTED FOREIGN EARNINGS
An actual repatriation from our foreign subsidiaries could still be subject to additional foreign withholding taxes. We have analyzed our global working capital and cash requirements and continue to be indefinitely reinvested in our undistributed earnings, except for amounts in excess of our working capital and cash requirements. We have recorded any potential withholding tax liabilities, if necessary, attributable to repatriation.
OTHER TAX MATTERS
We file income tax returns for U.S. federal purposes and in various state jurisdictions. We also file income tax returns in various foreign jurisdictions, principally Canada, Ireland, Mexico, and Singapore. The U.S. and most state income tax returns for years prior to 2020 are closed to examination by applicable tax authorities. Canadian and Mexican income tax returns are generally open for audit for tax years 2020 and forward, and Ireland income tax returns are open for audit for tax years 2021 and forward.
Certain taxpayers may elect to transfer an eligible credit to an unrelated transferee taxpayer where the transferee taxpayer is then able to use the transferred tax credit against its own taxable income. During the years ended December 31, 2025, 2024, and 2023, we executed agreements with eligible taxpayers to purchase federal tax credits of $266 million, $260 million, and $270 million, respectively, which will be used against our federal tax liability. The discounts negotiated for the transfer of eligible federal tax credits of $23 million, $20 million, and $16 million were recorded as an income tax benefit in the Consolidated Statements of Income for the years ended December 31, 2025, 2024, and 2023, respectively.
On July 4, 2025, the OBBB was signed into law in the U.S., which includes a broad range of tax reform provisions. The OBBB resulted in no significant impacts to our consolidated financial statements.
UNRECOGNIZED TAX BENEFITS
The following is a reconciliation of the changes in the gross balance of unrecognized tax benefits:
For the Year Ended December 31,
(in millions)202520242023
Balance, beginning of the period$12 $13 $15 
Increases related to tax positions taken during the current year3 
Increases (decreases) related to tax positions taken during the prior year17 (1)(2)
Decreases related to lapse of applicable statute of limitations (2)(3)
Balance, end of the period$32 $12 $13 
The total amount of unrecognized tax benefits that would reduce the effective tax rate if recognized is $28 million after considering the federal impact of state income taxes.
We accrue interest and penalties on our uncertain tax positions as a component of our provision for income taxes. We recognized $5 million, $1 million, and $1 million of expense related to interest and penalties for uncertain tax positions for each of the years ended December 31, 2025, 2024, and 2023, respectively. We had a total of $9 million and $3 million accrued for interest and penalties for our uncertain tax positions reported as part of other non-current liabilities as of both December 31, 2025 and 2024.

Historical Timeline

Fiscal YearFiled
2025Feb 24, 2026Showing above
2024Feb 25, 2025
2023Feb 22, 2024
2022Feb 23, 2023
2021Feb 24, 2022
2020Feb 25, 2021
2019Feb 27, 2020
2018Feb 28, 2019
2017Feb 14, 2018
2016Feb 14, 2017
2015Feb 23, 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.