Income Taxes
Income (loss) from continuing operations before income taxes consisted of the following:
Years Ended December 31,
202520242023
U.S.$146,384 $(112,261)$(112,437)
International46,140 59,934 68,517 
Total$192,524 $(52,327)$(43,920)

The provision (benefit) for income taxes consisted of the following:
Years Ended December 31,
202520242023
U.S. Federal:
Current$(9,440)$2,535 $32,784 
Deferred28,050 (138,444)(31,591)
18,610 (135,909)1,193 
U.S. State and Local:
Current2,912 1,375 9,083 
Deferred7,368 (41,416)(9,973)
10,280 (40,041)(890)
International:
Current15,950 14,971 11,266 
Deferred2,987 6,150 5,778 
18,937 21,121 17,044 
Total current9,422 18,881 53,133 
Total deferred38,405 (173,710)(35,786)
Total provision (benefit) for income taxes$47,827 $(154,829)$17,347 
Effective tax rate24.8 %295.9 %(39.5)%
The benefit for income taxes for 2024 includes a tax benefit of $164 million primarily due to an affiliate reorganization as well as a $6 million benefit related to a state interest valuation allowance release.
The effective tax rate for 2023 includes a benefit of $2 million on the aggregate $124 million goodwill impairment charge as the majority of this charge is nondeductible.
In the fourth quarter of 2025, we prospectively adopted ASU 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures. A reconciliation of income taxes computed at the federal statutory rate and our provision or benefit for income taxes consisted of the following:
Years Ended December 31,
202520242023
U.S. Federal statutory tax rate$40,430 21.0%$(10,989)$(9,223)
State and local income taxes, net of federal benefit (1)
8,126 4.2%(31,632)(703)
Foreign tax effects
Canada
Capital gain4,381 2.3%
Other(550)(0.3)%
Other foreign jurisdictions5,131 2.7%
Impact of foreign operations taxed at rates other than the U.S. statutory rate (2)
4,595 2,779 
Effect of cross-border tax laws
Global intangible low-taxed income
566 0.3%
Subpart F income
2,009 1.0%
Other(489)(0.3)%
U.S. tax impacts of foreign income in the U.S. (3)
7,983 1,099 
Changes in valuation allowances 2,100 — 
Nontaxable or nondeductible items
Unrealized stock compensation benefits(2,057)(1.1)%1,686 574 
Surrender of company-owned life insurance policies 8,139 — 
Nondeductible officer's compensation5,123 2.7%5,992 — 
Affiliate reorganization (141,723)— 
Goodwill impairment — 24,437 
Changes in unrecognized tax benefits
Accrual/release of uncertain tax amounts related to foreign operations (4)
(14,328)(7.4)%(829)(2,829)
Other adjustments(515)(0.3)%(151)1,213 
Provision (benefit) for income taxes$47,827 24.8%$(154,829)$17,347 
(1)    State taxes in California, Illinois, New York and New Jersey make up the majority (greater than 50%) of the tax effect in this category for the year ended December 31, 2025. Also includes a benefit of $22 million related to the affiliate reorganization and a benefit of $6 million related to a state interest valuation allowance release for the year ended December 31, 2024.
(2)    Includes a charge of $1 million for a change in tax rates for the year ended December 31, 2024.
(3)    Includes a charge of $2 million for the loss of the GILTI deduction as well as a charge of $2 million for withholding tax for the year ended December 31, 2024.
(4) Includes a benefit of $4 million related to interest on unrecognized tax benefits for the year ended December 31, 2025.
Deferred tax liabilities and assets consisted of the following:
December 31,
20252024
Deferred tax liabilities:
Deferred profit (for tax purposes) on sale to finance subsidiary$(44,759)$(53,370)
Lease revenue and related depreciation(167,126)(183,237)
Intangible assets(53,334)(52,773)
Operating lease liability(26,135)(27,857)
Other(12,208)(10,847)
Gross deferred tax liabilities(303,562)(328,084)
Deferred tax assets:
Depreciation
9,314 32,539 
Postretirement medical benefits18,949 20,108 
Pension16,610 16,948 
Operating lease asset31,411 31,429 
Long-term incentives3,773 5,914 
Net operating and capital losses248,099 257,186 
Tax credit carry forwards67,376 65,697 
Section 163j carryforward76,309 86,075 
Tax uncertainties gross-up3,379 4,568 
Other63,387 57,915 
Gross deferred tax assets538,607 578,379 
Less: Valuation allowance(224,922)(206,441)
Net deferred tax assets313,685 371,938 
Total deferred taxes, net$10,123 $43,854 
The valuation allowance relates primarily to certain foreign, state and local net operating loss and tax credit carryforwards that will more-likely-than-not expire without being utilized.
We have a federal net operating loss carryforward of $224 million as of December 31, 2025, that has an unlimited carryforward period. We have net operating loss carryforwards in international jurisdictions of $422 million as of December 31, 2025, of which $118 million can be carried forward indefinitely and the remainder expire over the next 20 years. We also have net operating loss carryforwards in most states totaling $1 billion that will expire over the next 20 years. In addition, we have tax credit carryforwards of $67 million, of which $52 million can be carried forward indefinitely and the remainder expire over the next 10 years.

As of December 31, 2025, we assert that we are permanently reinvested in our pre-1987 and post-2017 undistributed earnings of $587 million as well as all other outside basis differences. While a determination of the full liability that would be incurred if these earnings were repatriated is not practicable, we have estimated the withholding taxes would be approximately $3 million.
A reconciliation of the amount of unrecognized tax benefits is as follows:
Years Ended December 31,
202520242023
Balance at beginning of year$27,037 $30,232 $33,300 
Increases from prior period positions — 343 
Decreases from prior period positions(39)(955)(524)
Increases from current period positions 73 400 
Decreases relating to settlements with tax authorities(52)(1,467)(350)
Reductions from lapse of applicable statute of limitations(10,845)(846)(2,937)
Balance at end of year$16,101 $27,037 $30,232 
The amount of the unrecognized tax benefits at December 31, 2025, 2024 and 2023 that would affect the effective tax rate if recognized was $13 million, $24 million and $26 million, respectively.
We recognize interest and penalties related to uncertain tax positions in our provision for income taxes. The amount included in our provision for income taxes related to interest and penalties on uncertain tax positions for the year ended December 31, 2025 was a benefit of $4 million and for each of the years ended December 31, 2024 and 2023 were not significant. We had approximately $4 million accrued for the payment of interest and penalties at December 31, 2024.

Cash income tax payments, net of refunds consisted of the following:
Year Ended December 31, 2025
Federal $(6,836)
State
California
1,480 
Other
1,717 
Foreign
Barbados
1,678 
Canada9,828 
France3,595 
Japan
2,097 
Other2,500 
Cash income tax payments, net of refunds$16,059 
Cash income tax payments, net of refunds for the years ended December 31, 2024 and 2023 were $45,478 and $22,626, respectively.

Other Tax Matters
The One Big Beautiful Bill Act that was enacted on July 4, 2025, did not have a material impact on our tax provision.
With regard to U.S. Federal income tax, all positions are effectively settled with the Internal Revenue Service for years prior to 2022. On a state and local level, returns for most jurisdictions are closed through 2019. For our significant non-U.S. jurisdictions, Canada is closed to examination through 2020 except for a specific issue under current exam, and France, Germany and the U.K. are closed through 2019, 2020, and 2023 respectively. We also have other less significant tax filings currently subject to examination, including an appeal of a specific issue in India.
We regularly assess the likelihood of tax adjustments in each of the tax jurisdictions in which we have operations and account for the related financial statement implications. We believe we have established tax reserves that are appropriate given the possibility of tax adjustments. However, determining the appropriate level of tax reserves requires judgment regarding the uncertain application of tax law and the possibility of tax adjustments. Future changes in tax reserve requirements could have a material positive or negative impact on our results of operations, financial position and cash flows.

Historical Timeline

Fiscal YearFiled
2025Feb 19, 2026Showing above
2024Feb 21, 2025
2023Feb 20, 2024
2022Feb 17, 2023
2021Feb 22, 2022
2020Feb 19, 2021
2019Feb 20, 2020
2018Feb 20, 2019
2017Feb 22, 2018
2016Feb 22, 2017
2015Feb 22, 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.