NOTE 25 – Income Taxes

Income before income tax expense for the year ended December 31, 2025 (in thousands):

Domestic

 

$

893,458

 

Foreign

 

 

(22,319

)

Income before income tax expense

 

$

871,139

 

The provision for income taxes consists of the following (in thousands):

 

 

Year Ended December 31,

 

 

 

2025

 

 

2024

 

 

2023

 

Current taxes:

 

 

 

 

 

 

 

 

 

Federal

 

$

156,134

 

 

$

177,076

 

 

$

127,771

 

State

 

 

45,804

 

 

 

51,192

 

 

 

39,361

 

Foreign

 

 

6,521

 

 

 

(565

)

 

 

1,056

 

 

 

 

208,459

 

 

 

227,703

 

 

 

168,188

 

Deferred taxes:

 

 

 

 

 

 

 

 

 

Federal

 

 

(21,766

)

 

 

(26,804

)

 

 

9,067

 

State

 

 

(1,997

)

 

 

(4,456

)

 

 

2,917

 

Foreign

 

 

2,664

 

 

 

622

 

 

 

3,984

 

 

 

 

(21,099

)

 

 

(30,638

)

 

 

15,968

 

Provision for income taxes:

 

 

 

 

 

 

 

 

 

Federal

 

$

134,368

 

 

$

150,272

 

 

$

136,838

 

State

 

 

43,807

 

 

 

46,736

 

 

 

42,278

 

Foreign

 

 

9,185

 

 

 

57

 

 

 

5,040

 

 

 

$

187,360

 

 

$

197,065

 

 

$

184,156

 

The following table presents income taxes paid, net of refunds, disaggregated by jurisdiction for the year ended December 31, 2025 (in thousands):

Federal (includes amounts paid for transferable tax credits)

 

$

132,468

 

State and Local

 

 

 

Missouri *

 

 

10,083

 

Other

 

 

44,000

 

 

 

 

54,083

 

Foreign

 

 

 

Ireland *

 

 

12,581

 

Other

 

 

1,191

 

 

 

 

13,772

 

Total income taxes paid

 

$

200,323

 

* Exceeds 5% of total income taxes paid, net of refunds, for the year ended December 31, 2025.

As discussed in Note 2 – Summary of Significant Accounting Policies, we adopted ASU 2023-09 on January 1, 2025, on a prospective basis. As a result, our rate reconciliation for the year ended December 31, 2025, is presented in accordance with the new disclosure requirements, while the reconciliations for the years ended December 31, 2024 and 2023, respectively, continue to be presented under disclosure requirements in effect for those periods.

Reconciliation of the statutory federal income tax rate with our company’s effective income tax rate is as follows for the year ended December 31, 2025, after the adoption of ASU 2023-09 (in thousands):

 

 

Year Ended December 31, 2025

 

 

 

 

Income before income tax expense

 

$

871,139

 

 

 

 

Statutory rate

 

 

182,939

 

 

 

21.0

%

State and local income taxes, net of federal income tax effect *

 

 

34,204

 

 

 

3.9

%

Foreign tax effects:

 

 

 

 

 

 

Other foreign jurisdictions

 

 

13,859

 

 

 

1.6

%

Effect of cross-border tax laws

 

 

807

 

 

 

0.1

%

Tax credits:

 

 

 

 

 

 

Purchased federal tax credit benefit

 

 

(16,347

)

 

 

(1.9

)%

Other tax credits

 

 

(3,020

)

 

 

(0.3

)%

Nontaxable or nondeductible items:

 

 

 

 

 

 

Share-based payment awards

 

 

(43,103

)

 

 

(5.0

)%

Compensation in excess of $1 million

 

 

11,577

 

 

 

1.3

%

Other nondeductible items

 

 

5,739

 

 

 

0.7

%

Changes in unrecognized tax benefits

 

 

54

 

 

 

0.0

%

Other adjustments

 

 

651

 

 

 

0.1

%

Effective tax rate

 

$

187,360

 

 

 

21.5

%

* The states and local jurisdictions that make up the majority (greater than 50%) of the state and local income tax, net of federal income tax effect are New York, Missouri, New York City, and California.

Reconciliation of the statutory federal income tax rate with our company’s effective income tax rate is as follows for the years ended December 31, 2024 and 2023, before the adoption of ASU 2023-09 (in thousands):

 

Year Ended December 31,

 

 

2024

 

 

2023

 

Statutory rate

$

194,973

 

 

$

148,405

 

State income taxes, net of federal income tax

 

35,986

 

 

 

34,012

 

Non-deductible business expenses

 

16,857

 

 

 

25,177

 

Change in valuation allowance

 

10,565

 

 

 

21,931

 

Foreign tax rate difference

 

(3,104

)

 

 

(2,471

)

Federal tax credits

 

(14,396

)

 

 

(7,002

)

Excess tax benefit from stock-based compensation

 

(44,717

)

 

 

(31,109

)

Other, net

 

901

 

 

 

(4,787

)

 

$

197,065

 

 

$

184,156

 

 

Tax effect of temporary differences and carryforwards that comprise significant portions of deferred tax assets and liabilities (in thousands):

 

 

December 31,

 

 

 

2025

 

 

2024

 

Deferred tax assets:

 

 

 

 

 

 

Lease liabilities

 

$

213,475

 

 

$

222,808

 

Deferred compensation

 

 

89,954

 

 

 

90,083

 

Accrued expenses

 

 

73,007

 

 

 

35,782

 

Net operating loss carryforwards

 

 

65,340

 

 

 

56,882

 

Receivable reserves

 

 

53,424

 

 

 

55,467

 

Unrealized loss on investments

 

 

28,649

 

 

 

54,706

 

Other

 

 

4,643

 

 

 

 

Total deferred tax assets

 

 

528,492

 

 

 

515,728

 

Valuation allowance

 

 

(59,984

)

 

 

(57,250

)

 

 

 

468,508

 

 

 

458,478

 

Deferred tax liabilities:

 

 

 

 

 

 

Lease right-of-use assets

 

 

(197,440

)

 

 

(207,821

)

Goodwill and other intangibles

 

 

(92,232

)

 

 

(81,569

)

Depreciation

 

 

(20,720

)

 

 

(5,069

)

Prepaid expenses

 

 

(6,912

)

 

 

(8,031

)

Other

 

 

 

 

 

(3,610

)

 

 

 

(317,304

)

 

 

(306,100

)

Net deferred tax asset

 

$

151,204

 

 

$

152,378

 

Our net deferred tax asset at December 31, 2025, includes net operating loss carryforwards of $120.7 million that expire between 2025 and 2044. Certain of our net operating loss carryforwards do not expire. A valuation allowance is recorded to the extent that it is more likely than not that any portion of the deferred tax asset will not be realized. The valuation allowance was increased by $2.7 million. We believe the realization of the remaining net deferred tax asset of $151.2 million is more likely than not based on the ability to carry back certain tax attributes against prior year taxable income for tax years before 2025 and to carry forward net operating losses indefinitely after 2025, and expectations of future taxable income, which is supported by a history of cumulative income.

The material amount of the deferred tax asset valuation allowance relates to the net operating loss carryforwards in our foreign jurisdictions, primarily in the U.K., Germany, and Canada. These foreign net operating loss carryforwards total $51.9 million of the deferred tax asset valuation allowance. The negative evidence considered was the three-year cumulative loss analysis at the entity and jurisdictional level. We could not identify enough positive evidence, through forecasts, the reversal of deferred tax liabilities, or tax planning strategies, to overcome the negative evidence from the three-year cumulative loss.

We have $3.9 million of the deferred tax asset valuation allowance related to other foreign components of the deferred tax asset, mainly deferred compensation from restricted stock units and cash debentures. The negative evidence considered here was the three-year cumulative loss analysis as well. We have an additional $2.7 million of state net operating loss carryforwards included in the deferred tax asset valuation allowance. The negative evidence considered was a three-year cumulative loss analysis for a separate entity filing state returns. We have approximately $9.2 million of net operating loss carryforwards that do not require a valuation allowance.

At December 31, 2025, the Company’s current income tax payable, included in accounts payable and accrued expenses, was a debit balance of $29.0 million and will be used to reduce future income tax payments. At December 31, 2024, the Company’s current income tax payable, included in accounts payable and accrued expenses, was $5.8 million. The current tax receivable, included in other assets, is $64.5 million and $30.1 million as of December 31, 2025 and 2024, respectively.

As of December 31, 2025, we considered all undistributed earnings of non-U.S. subsidiaries to be permanently reinvested. Therefore, we have not provided for any U.S. deferred income taxes. Because the time or manner of repatriation is uncertain, we cannot determine the impact of local taxes, withholding taxes and foreign tax credits associated with the future repatriation of such earnings, and therefore cannot quantify the tax liability that would be payable in the event all such foreign earnings are repatriated.

Uncertain Tax Positions

As of December 31, 2025 and 2024, we had $5.5 million and $5.5 million, respectively, of gross unrecognized tax benefits, all of which, if recognized, would impact the effective tax rate. We recognize interest and penalties related to uncertain tax positions in provision for income taxes in the consolidated statements of operations. As of December 31, 2025 and 2024, we had accrued interest and penalties of $0.4 million and $0.3 million, respectively, before benefit of federal tax deduction, included in accounts payable and accrued expenses in our consolidated statements of financial condition. The amount of interest and penalties recognized in our consolidated statements of operations for the years ended December 31, 2025, 2024, and 2023, was not significant.

The following table summarizes the activity related to our company’s unrecognized tax benefits from January 1, 2023 to December 31, 2025 (in thousands):

 

 

Year Ended December 31,

 

 

 

2025

 

 

2024

 

 

2023

 

Beginning balance

 

$

5,505

 

 

$

5,430

 

 

$

5,271

 

Increase related to prior year tax positions

 

 

 

 

 

428

 

 

 

112

 

Decrease related to prior year tax positions

 

 

(261

)

 

 

(324

)

 

 

(63

)

Increase related to current year tax positions

 

 

1,000

 

 

 

1,072

 

 

 

1,083

 

Decrease related to settlements with taxing authorities

 

 

 

 

 

(499

)

 

 

 

Decrease related to lapsing of statute of limitations

 

 

(779

)

 

 

(602

)

 

 

(973

)

Ending balance

 

$

5,465

 

 

$

5,505

 

 

$

5,430

 

We file income tax returns with the U.S. federal jurisdiction, various states, and certain foreign jurisdictions. We are not subject to U.S. federal examination for taxable years before 2022. We are not subject to certain state and local, or non-U.S. income tax examinations for taxable years before 2015.

On July 4, 2025, the reconciliation bill, commonly referred to as the One Big Beautiful Bill Act (OBBBA), was signed into law in the U.S., which includes a broad range of tax reform provisions. Beginning in 2025, the OBBBA provides an elective deduction for domestic research and development expenses, a reinstatement of elective 100% first-year bonus depreciation, and repeal of non-U.S. corporations’ fiscal year-end. We elected to expense its domestic research and development expenditures and take 100% bonus depreciation for qualified assets for U.S. tax purposes. We will continue to monitor the impact of the OBBBA and the range of potential outcomes, which will depend on our facts in each year and anticipated guidance from the U.S. Department of the Treasury.

Historical Timeline

Fiscal YearFiled
2025Feb 24, 2026Showing above
2024Feb 26, 2025
2023Feb 16, 2024
2022Feb 17, 2023
2021Feb 18, 2022
2020Feb 19, 2021
2019Feb 19, 2020
2018Feb 20, 2019
2017Feb 26, 2018
2016Feb 23, 2017
2015Mar 1, 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.