OSHKOSH CORP Income Taxes Disclosure

7. Income Taxes

In 2025, state taxes in California, Florida, Maryland, New Jersey, New York and Pennsylvania made up the majority of the state income tax. In 2024, state taxes in California, Florida, Georgia, Michigan, New York, Pennsylvania and Texas made up the majority of the state income tax. In 2023, state taxes in California, Colorado, Michigan, New Jersey, Pennsylvania and Wisconsin made up the majority of the state income tax.

Cash paid for income taxes, net of refunds includes cash paid for the purchase of transferable tax credits of $10.2 million, $68.3 million and $6.8 million in 2025, 2024 and 2023, respectively. No state or foreign jurisdictions exceeded 5% of total income taxes paid, net of refunds.

As of December 31, 2025, the Company had $26.4 million of net operating loss carryforwards available to reduce future taxable income of certain foreign subsidiaries in countries which allow such losses to be carried forward anywhere from five years to an unlimited period. In addition, the Company had $156.0 million of state net operating loss carryforwards, which can be carried forward anywhere from fifteen years to an unlimited period and state credit carryforwards of $35.0 million, which are subject to expiration in 2029 to 2039. Deferred tax assets for foreign net operating loss carryforwards, state net operating loss carryforwards, state tax credit carryforwards and foreign tax credit carryforwards were $6.7 million, $7.9 million, $22.5 million and $15.1 million, respectively, as of December 31, 2025. Amounts are reviewed for recoverability based on historical taxable income, the expected reversals of existing temporary differences, tax-planning strategies and projections of future taxable income. The Company maintains valuation allowances against domestic deferred tax assets, state tax credit carryforwards, foreign net deferred tax assets, including net operating losses, and foreign tax credit deferred tax assets of $2.4 million, $0.2 million, $7.1 million and $11.7 million, respectively, as of December 31, 2025.

At December 31, 2025, the Company had undistributed earnings of $523.4 million from its investment in non-U.S. subsidiaries. The Company has not recognized deferred tax liabilities for temporary differences related to certain of the Company’s foreign operations as the Company considers that a portion of its undistributed earnings in those subsidiaries are intended to be indefinitely reinvested. Should the Company’s undistributed earnings from its investment in those non-U.S. subsidiaries be distributed in the future in the form of dividends or otherwise, the Company may be subject to foreign and domestic income taxes and withholding taxes estimated at $27.4 million, including the impact of the regulations discussed below.

On August 21, 2020, the U.S. Treasury Department and the U.S. Internal Revenue Service (IRS) released final regulations related to the Tax Reform Act (the “tax regulations”) and the foreign dividends received deduction and global intangible low-taxed income. The tax regulations contained language that modified certain provisions of the Tax Reform Act and previously issued guidance and are effective retroactively to the Company’s fiscal 2018 tax year and purport to cause certain intercompany transactions the Company engaged in during 2018 to produce U.S. taxable income upon a subsequent distribution from a controlled foreign corporation. The Company has analyzed the tax regulations and concluded that the U.S. Treasury Department exceeded regulatory authority and that the tax regulations are contrary to the congressional intent of the underlying statute. The Company believes it has strong arguments in favor of its position and that it has met the more likely than not recognition threshold that its position will be sustained. The Company intends to vigorously defend its position, however, due to the uncertainty involved in challenging the validity of regulations as well as a potential litigation process, there can be no assurances that the tax regulations will be invalidated, modified or that a court of law will rule in favor of the Company. An unfavorable resolution of this issue would result in $19.2 million of tax liability if the Company were to distribute the earnings to the United States, which is included in the $27.4 million disclosed withholding tax above.

Settlement with taxing authorities in 2025 related to the resolution of a multi-year federal income tax audit. As of December 31, 2025, net unrecognized tax benefits, excluding interest and penalties, of $34.2 million would affect the Company’s effective tax rate if recognized. The Company recognizes accrued interest and penalties, if any, related to unrecognized tax benefits in the “Provision for income taxes” in the Consolidated Statements of Income. The Company recognized income of $3.3 million, expense of $4.0 million and income of $0.3 million in 2025, 2024 and 2023, respectively, related to interest and penalties on unrecognized tax benefits. The Company had accruals for the payment of interest and penalties of $8.6 million and $11.8 million at December 31, 2025 and 2024, respectively.

The Company files federal income tax returns, as well as multiple state, local and non-U.S. jurisdiction tax returns. The Company is regularly audited by federal, state and foreign tax authorities. As of December 31, 2025, tax years open for examination under applicable statutes were as follows: