Income Taxes
We adopted ASU 2023-09 “Income Taxes (Topic 740): Improvements to Income Tax Disclosures” on a prospective basis beginning with the year ended December 31, 2025. The following table presents required disclosure pursuant to ASU 2023-09 and reconciles the statutory U.S. federal income tax amount and rate to our effective tax amount and rate for continuing operations for the year ended December 31, 2025:
Year ended December 31,
(dollars in thousands)
2025
Statutory rate$208,438 21.0 %
Tax credits:
Research credit(4,037)(0.4)
Low-income housing credit(2,791)(0.3)
Nondeductible items10,107 1.0 
Expired capital losses14,020 1.4 
Other, net(7,879)(0.7)
Changes in valuation allowances(10,982)(1.1)
State and local income taxes, net of federal effect34,756 3.5 
Changes in unrecognized tax benefits6,084 0.6 
Effective tax rate$247,716 25.0 %
The following table presents the required disclosures prior to our adoption of ASU 2023-09 and reconciles the statutory U.S. federal income tax rate to our effective tax rate for continuing operations for the years ended December 31, 2024 and 2023:
 
Years ended December 31,20242023
Statutory rate21.0 %21.0 %
State tax, net of federal benefit2.3 3.8 
Business credits(2.0)(1.3)
Other, net2.5 1.8 
Effective tax rate23.8 %25.3 %
The effective tax rate varies from the statutory U.S. federal rate of 21 percent primarily due to the impact of state taxes, net of federal benefit, for the year ended December 31, 2025 and due to business tax credits and the impact of state taxes, net of federal benefit, for the years ended December 31, 2024 and 2023. For the year ended December 31, 2025, California, New York, New Jersey, Illinois, and Delaware comprised the majority of the domestic, state, and local income taxes, net of federal effect category. For the year ended December 31, 2024, New York, New Jersey, Delaware, California, and Illinois comprised the majority of the domestic, state, and local income taxes, net of federal effect category. For the year ended December 31, 2023, New Jersey, New York, Delaware, Illinois, California, and Massachusetts comprised the majority of the domestic, state, and local income taxes, net of federal effect category.
Income tax expense consists of:
 
As of December 31,
(dollars in thousands)
202520242023
Current provision (benefit):
U.S. Federal$149,056 $181,132 $175,977 
U.S. State48,344 43,506 44,152 
Total current provision (benefit)197,400 224,638 220,129 
Deferred provision (benefit):
U.S. Federal47,181 (19,032)(20,687)
U.S. State3,135 (15,295)(2,537)
Total deferred provision (benefit)50,316 (34,327)(23,224)
Provision for income tax expense$247,716 $190,311 $196,905 
The tax effect of temporary differences that give rise to deferred tax assets and liabilities is summarized below.

As of December 31,
(dollars in thousands)
20252024
Deferred tax assets:
Loan reserves$381,894 $376,029 
Net unrealized losses13,446 21,209 
Accrued expenses not currently deductible18,384 19,841 
Unrecorded tax benefits13,574 12,008 
Research and development costs— 38,119 
Stock-based compensation plans12,508 12,885 
Acquired intangible assets14,173 16,394 
Other1,129 1,785 
Total deferred tax assets455,108 498,270 
Deferred tax liabilities:
Student loan premiums and discounts, net25,303 22,873 
Fixed assets9,806 7,708 
Federal deferred for state receivable1,344 1,908 
Research and development costs5,972 — 
Other3,821 402 
Total deferred tax liabilities46,246 32,891 
Net deferred tax assets$408,862 $465,379 
Included in operating loss carryovers are state net operating losses of $179 million and $234 million as of December 31, 2025 and 2024, respectively. The Company has recorded a valuation allowance against these net operating losses of $179 million and $234 million, respectively. Also included in operating loss carryovers is a capital loss of $12 million and $23 million as of December 31, 2025 and 2024, respectively. The Company has recorded a full valuation allowance against this capital loss. The valuation allowance is primarily attributable to deferred tax assets for state net operating losses and capital losses that management believes are more likely than not to expire prior to being realized. There is no valuation allowance included in net unrealized losses as of December 31, 2025. There is a valuation allowance of $5 million included in net unrealized losses as of December 31, 2024.
The ultimate realization of the deferred tax assets is dependent upon the generation of future taxable income of the appropriate character (i.e., capital or ordinary) during the period in which the temporary differences become deductible. Management considers, among other things, the scheduled reversals of deferred tax liabilities and the history of positive taxable income in evaluating the realizability of the deferred tax assets. Management believes that it is more likely than not that the results of future operations will generate sufficient taxable income to realize our deferred tax assets (other than state net operating loss and capital loss carryovers as outlined above).
As of December 31, 2025, the state net operating loss carryforwards will begin to expire in 2030 and the capital losses began to expire in 2025.
Accounting for Uncertainty in Income Taxes
The following table summarizes changes in unrecognized tax benefits:
 
As of December 31,
(dollars in thousands)
202520242023
Unrecognized tax benefits at beginning of year$48,407 $68,123 $79,366 
Increases resulting from tax positions taken during a prior period816 1,232 1,204 
Decreases resulting from tax positions taken during a prior period(1)(1,890)(250)
Increases resulting from tax positions taken during the current period3,203 3,218 2,711 
Decreases related to settlements with taxing authorities— (18,349)(10,089)
Reductions related to the lapse of statute of limitations(1,832)(3,927)(4,819)
Unrecognized tax benefits at end of year$50,593 $48,407 $68,123 
As of December 31, 2025, the gross unrecognized tax benefits are $51 million. Included in the $51 million are $41 million of unrecognized tax benefits that, if recognized, would favorably impact the effective tax rate.

Tax-related interest and penalty expense is reported as a component of income tax expense. As of December 31, 2025, 2024, and 2023, the total amount of income tax-related accrued interest and penalties, net of related benefit, recognized in the consolidated balance sheets was $15 million, $11 million, and $8 million, respectively.

For the years ended December 31, 2025, 2024, and 2023, the total amount of income tax-related accrued interest, net of related tax benefit, recognized in the consolidated statements of income was $4 million, $3 million, and $2 million, respectively.
The Company or one of its subsidiaries files income tax returns at the U.S. federal level and in most U.S. states. U.S. federal income tax returns filed for years 2021 and prior are no longer subject to examination. Various combinations of subsidiaries, tax years, and jurisdictions remain open for review, subject to statute of limitations periods (typically three to four prior years). We do not expect the resolution of open audits to have a material impact on our unrecognized tax benefits.
Cash Taxes Paid
We adopted ASU 2023-09 on a prospective basis for the year ended December 31, 2025 and have included the following table as a result of our adoption, which presents income taxes paid (net of refunds received) for the year ended December 31, 2025:
Year ended December 31,
(dollars in thousands)
2025
Income taxes paid (net of refunds received):
U.S. federal$129,000 
U.S. state and local:
California9,400 
Other28,803 
Total U.S. state and local38,203 
Total income taxes paid (net of refunds received)$167,203 
Below is a summary of income taxes paid for the years ended December 31, 2024 and 2023:
Years ended December 31,
(dollars in thousands)
20242023
Cash disbursement made for:
Income taxes paid$243,341 $191,690 
Income taxes refunded (1,395)(8,201)

Historical Timeline

Fiscal YearFiled
2025Feb 19, 2026Showing above
2024Feb 20, 2025
2023Feb 22, 2024
2022Feb 23, 2023
2021Feb 24, 2022
2020Feb 25, 2021
2019Feb 28, 2020
2018Feb 28, 2019
2017Feb 23, 2018
2016Feb 24, 2017
2015Feb 26, 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.