Significant components of the provision for income tax expense (benefit) are as follows:
Year Ended December 31,
202520242023
(in thousands)
Current:
  Federal$(6,176)$39,122 $1,250 
  Foreign345,460 253,442 229,073 
  State21,005 24,308 23,171 
Total current360,289 316,872 253,494 
Deferred:
  Federal55,229 (557,399)5,982 
  Foreign(68,207)(126,423)(51,209)
  State(7,524)(24,748)1,209 
Total deferred(20,502)(708,570)(44,018)
Income tax expense (benefit)$339,787 $(391,698)$209,476 
The domestic income before income taxes was $145.6 million, $31.8 million and $237.5 million for 2025, 2024 and 2023, respectively. Foreign income before income taxes was $884.9 million, $707.6 million and $675.8 million for the years ended December 31, 2025, 2024 and 2023, respectively.
Significant components of our deferred tax liabilities and assets are as follows:
December 31,
20252024
(in thousands)
Deferred tax liabilities:
          Intangible and fixed assets$396,428 $282,200 
          Leases233,421 210,904 
Mark to market50,780 49,691 
          Prepaid expenses10,023 3,802 
          Other9,023 779 
Total deferred tax liabilities699,675 547,376 
Deferred tax assets:
          Net operating loss carryforwards851,765 763,205 
          Leases 277,872 244,476 
          Accrued expenses209,327 251,416 
          Capitalized research and development107,585 90,477 
          Interest limitation73,037 69,128 
          Foreign tax and other credit carryforwards59,294 51,153 
          Other45,270 61,555 
          Intangible and fixed assets16,358 12,411 
          Equity compensation14,111 10,831 
Total gross deferred tax assets1,654,619 1,554,652 
          Valuation allowance587,285 569,495 
Total net deferred tax assets1,067,334 985,157 
Net deferred tax assets$367,659 $437,781 
Each reporting period, we evaluate the realizability of all of our deferred tax assets in each tax jurisdiction. The Company recorded valuation allowances of $587.3 million and $569.5 million as of December 31, 2025 and 2024, respectively. Deferred income tax assets and liabilities are recorded related to net operating losses and temporary differences between the book and tax basis of assets and liabilities expected to produce tax deductions and income in the future. The realization of these assets depends on recognition of sufficient future taxable income in specific tax jurisdictions in which those temporary differences or net operating losses relate.
In assessing the need for a valuation allowance, the Company considers whether it is more likely than not that some portion or all of the deferred tax assets will not be realized using available positive and negative evidence, including future reversals of temporary differences, tax-planning strategies and future taxable income, to estimate whether sufficient future taxable income will be generated to permit use of deferred tax assets. A significant piece of objective negative evidence evaluated is the cumulative loss incurred over recent years. Such objective negative evidence limits the Company’s ability to consider other subjective positive evidence.
At December 31, 2025, the valuation allowance primarily relates to investments in consolidated partnership and various state and foreign operating losses.
At December 31, 2025 and 2024, we recorded a net deferred tax asset of $367.7 million and $437.8 million, respectively, due principally to differences in financial reporting and tax bases in assets acquired in business combinations.
As of December 31, 2025, we have United States federal, state and foreign deferred tax assets related to net operating loss carryforwards of $254.4 million, $148.7 million and $448.7 million, respectively. Based on current statutory carryforward periods, the operating loss carryforwards will expire on various dates beginning in 2026. Our net operating losses may be subject to statutory limitations on the amount that can be used in any given year.
As of December 31, 2025, we have United States federal and state deferred tax assets related to credits of $40.4 million and $18.8 million, respectively. Based on current statutory carryforward periods, the credits will expire on various dates beginning in 2031.
A reconciliation of income tax computed at the United States federal statutory rates to income tax expense for the year ended December 31, 2025 is as follows:
Year Ended December 31,
2025
Total%
(in thousands)
U.S. federal statutory tax rate$216,411 21.0 %
State and local income taxes, net of federal income tax effect (2)
11,158 1.1 %
Foreign tax effects
Australia
Deferred taxes(12,374)(1.2)%
Other8,070 (1)0.8 %
Canada
Deferred taxes20,892 2.0 %
Other7,244 (1)0.7 %
Mexico
Nontaxable or nondeductible items25,001 2.4 %
Tax rate differential16,819 1.6 %
Other(352)(1)— %
Other foreign jurisdictions (3)
25,851 2.5 %
Effect of cross-border tax laws
Foreign income inclusion27,656 2.7 %
Other61 (1)— %
Changes in valuation allowances2,136 (1)0.2 %
Nontaxable or nondeductible items
Executive compensation in excess of $1 million35,771 3.5 %
Minority interest - nondeductible(9,856)(1)(1.0)%
Nontaxable income(15,061)(1.5)%
Other(7,237)(1)(0.7)%
Changes in unrecognized tax benefits2,528 (1)0.2 %
Return to provision(14,931)(1.3)%
Effective tax rate$339,787 33.0 %
(1)The impact of the individual reconciling item in this period is below the threshold and is not material to the users of the financial statements considering the nature and relative significance of the reconciling item.
(2)
State taxes in Illinois, New York, Pennsylvania, Tennessee and Texas made up the majority (greater than 50%) of the tax effect in this category.
(3)
All other foreign jurisdictions do not exceed the 5% threshold at the jurisdiction level in total or for individual reconciling items of the same nature within each jurisdiction.
Income tax expense is principally attributable to operational results in tax paying jurisdictions.
Amounts included in Foreign Tax Effects are impacted by changes in the mix of international earnings subject to various tax rates which can differ greatly in their proximity to the United States statutory rate and current and deferred adjustments related to payable and deferred tax assets.
Amounts included in the Effect of Cross-border Tax Laws include unfavorable inclusions for Subpart F.
Nondeductible items for all years presented include the impact of increased nondeductible expenses pursuant to the provisions of the Tax Cuts and Jobs Act (“TCJA”) including nondeductible executive compensation.
The following table reconciles the United States federal statutory income tax rate to our effective income tax rates for the years ended December 31, 2024 and 2023 prior to our adoption of ASU 2023-09:
Year Ended December 31,
20242023
(in thousands)
Income tax expense at United States statutory rate of 21%
$155,280 $187,854 
Differences between foreign and United States statutory rates
70,469 86,537 
State income taxes, net of federal tax benefits27,844 22,889 
Nondeductible items23,898 25,959 
United States income inclusions and exclusions(10,332)28,450 
Non-United States income inclusions and exclusions(9,466)(63,691)
Tax contingencies674 6,191 
Tax expense from acquired goodwill— 7,953 
Other, net166 784 
Change in valuation allowance(650,231)(93,450)
$(391,698)$209,476 
The following table summarizes the activity related to our unrecognized tax benefits:
Year Ended December 31,
202520242023
(in thousands)
Balance at January 1$29,692 $30,466 $22,996 
Additions:
          Increase for current year positions— 1,451 2,333 
          Increase for prior year positions1,505 1,001 4,453 
          Interest and penalties for prior years1,027 255 1,063 
Reductions:
          Statute lapse for prior year positions— (3)— 
          Settlements for prior year positions(878)(3,166)(379)
Foreign exchange187 (312)— 
Balance at December 31$31,533 $29,692 $30,466 
If we were to prevail on all uncertain tax positions, the net effect would be a decrease to our income tax provision of approximately $5.6 million. The remaining $25.9 million is related to various tax credits and would remain in place until the statute of limitation for those years expires. As of December 31, 2025, it is not expected that the total amounts of unrecognized tax benefits will increase or decrease materially within the next year.
We regularly assess the likelihood of additional assessments in each taxing jurisdiction resulting from current and subsequent years’ examinations. Liabilities for income taxes are established for future income tax assessments when it is probable there will be future assessments and the amount can be reasonably estimated. Once established, liabilities for uncertain tax positions are adjusted only when there is more information available or when an event occurs necessitating a change to the liabilities. As of December 31, 2025, we believe that the resolution of income tax matters for open years will not have a material effect on our consolidated financial statements although the resolution of income tax matters could impact our effective tax rate for a particular future period.
The tax years 2010 through 2025 remain open to examination by the primary tax jurisdictions to which we are subject.
Cash paid during the year for income taxes, net of refunds, are as follows:
Year Ended December 31,
2025
(in thousands)
State$33,366 
Foreign
Mexico102,806 
United Kingdom24,312 
Canada22,298 
Other foreign130,256 
Total$313,038 
There was no cash paid for United States federal income taxes as we generated a taxable loss for the year ended December 31, 2025 due to the provisions allowed within the One Big Beautiful Bill Act (the “Act”) discussed below.
Recent Tax Legislation
The Act was enacted on July 4, 2025 and makes key elements of the Tax Cuts and Jobs Act permanent, including 100% bonus depreciation, domestic research cost expensing, the business interest expense limitation and makes modifications to the international tax framework. The financial reporting implications of the Act were recorded in the income tax provision for the year ended December 31, 2025. The Company determined that the Act did not have a material impact on the consolidated financial statements for the year ended December 31, 2025. We will continue to evaluate the full impact of these legislative changes as additional guidance becomes available.

Historical Timeline

Fiscal YearFiled
2025Feb 19, 2026Showing above
2024Feb 21, 2025
2023Feb 22, 2024
2022Feb 23, 2023
2021Feb 23, 2022
2020Mar 1, 2021
2019Feb 27, 2020
2018Feb 28, 2019
2017Feb 27, 2018
2016Feb 23, 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.