Note 11—Income Taxes
The following are the domestic and foreign components of the Company’s income before income taxes (in thousands):
Year Ended December 31,
202520242023
Domestic$677,722 $579,338 $328,853 
Foreign(18,967)(72,036)(60,858)
Income before income taxes$658,755 $507,302 $267,995 
The following are the components of the provision for income taxes (in thousands):
Year Ended December 31,
202520242023
Current:   
Federal$11,117 $147,802 $120,049 
State and local22,740 33,019 24,827 
Foreign8,886 8,770 5,000 
Total current provision42,743 189,591 149,876 
Deferred:   
Federal160,917 (57,454)(51,822)
State and local15,280 (14,853)(7,842)
Foreign(3,489)(3,058)(1,157)
Total deferred provision172,708 (75,365)(60,821)
Total provision for income taxes$215,451 $114,226 $89,055 
A reconciliation of the statutory tax rate to the effective tax rate for the periods presented is as follows:
Year Ended December 31,
202520242023
(in thousands)%(in thousands)%(in thousands)%
United States federal statutory income tax rate$138,339 21.0 %$106,533 21.0 %$56,279 21.0 %
State and local income taxes, net of federal income tax effects (1)
30,224 4.6 14,355 2.8 13,579 5.1 
Foreign tax effects
United Kingdom
Statutory tax rate difference between the United Kingdom and United States(1,380)(0.2)(3,518)(0.7)(2,926)(1.1)
Stock-based awards (2)
(9,075)(1.4)(19,808)(3.9)(15,132)(5.6)
Other(2,244)(0.3)(978)(0.2)(792)(0.3)
Changes in valuation allowances (3)
16,784 2.6 42,776 8.4 34,210 12.7 
Other foreign jurisdictions2,136 0.3 2,368 0.5 1,263 0.5 
Effect of changes in tax laws or rates enacted in the current period— — — — — — 
Effect of cross-border tax laws(515)(0.1)0.0 (528)(0.2)
Tax credits
Research and development tax credits(17,781)(2.7)(30,038)(5.9)(23,918)(8.9)
Other33 0.0 — — — — 
Changes in valuation allowances— — — — — — 
Nontaxable or nondeductible items
Stock-based awards (2)
47,008 7.1 (4,462)(0.9)22,408 8.4 
Other7,130 1.1 5,228 1.0 4,270 1.5 
Changes in unrecognized tax benefits4,792 0.7 1,761 0.4 342 0.1 
Other adjustments— — — — — — 
Effective income tax rate$215,451 32.7 %$114,226 22.5 %$89,055 33.2 %
____________
(1)
For the years ended December 31, 2025, state and local taxes in California, New York, New York City and Illinois made up the majority (greater than 50 percent) of the tax effect in this category. For the years ended December 31, 2024 and 2023, state and local taxes in New York, New York City and Illinois made up the majority (greater than 50 percent) of the tax effect in this category.
(2)
Reconciling items for stock-based awards include nondeductible stock-based compensation and benefits or detriments from stock-based awards.
(3)
See discussion below regarding the valuation allowance associated with the United Kingdom (“U.K.”).
Certain percentages may not foot due to rounding.
Set forth below are income taxes paid, net of refunds (in thousands):
Year Ended December 31,
202520242023
United States - Federal$98,724 $134,717 $125,600 
United States - State - California*
9,361 **
United States - Other State and Local
29,740 18,027 23,286 
Foreign12,289 5,835 3,013 
Total income taxes paid, net of refunds$150,114 $158,579 $151,899 
___________
*
Income taxes paid, net of refunds, for California do not meet the disaggregation threshold in years 2024 and 2023. Such amounts are not presented as comparative disclosures because such disclosures are not required.
Set forth below are the tax effects of temporary differences that give rise to a significant portion of the deferred tax assets and deferred tax liabilities (in thousands):
As of December 31,
20252024
Reserves and allowances$5,971 $5,931 
Accrued expenses13,318 13,761 
Net operating losses321,226 292,022 
Research and development tax credit27,762 22,948 
Stock-based compensation33,483 23,431 
Prepaid expenses(1,472)(1,167)
Property and equipment(47,327)(27,171)
Intangibles (1)
139,822 161,060 
Capitalized software development costs6,836 181,862 
Operating lease assets(79,563)(57,846)
Operating lease liabilities102,815 69,493 
Other8,218 4,495 
Valuation allowance(475,389)(458,605)
Total deferred tax assets, net$55,700 $230,214 
____________
(1)
As of December 31, 2025 and 2024, includes intangibles associated with international restructuring, net of amortization, offset by a reserve for uncertain tax position. See discussion below.
Realization of the Company’s deferred tax assets is dependent primarily on the generation of future taxable income. As of each reporting date, the Company’s management considers historical, as well as future, projected taxable income along with other objectively verifiable evidence, both positive and negative. Objectively verifiable evidence includes the realization of tax attributes, assessment of tax credits and utilization of net operating loss carryforwards during the year. During 2025, management recorded an additional $17 million to maintain a full valuation allowance against its U.K. net deferred tax assets, based on the history of cumulative losses and the conclusion that future taxable income may not be available for the utilization of the deferred tax assets for U.K. income tax purposes. The Company expects to maintain this valuation allowance for the near term, until it becomes more likely than not that the benefit of these U.K. deferred tax assets will be realized by way of expected future taxable income. To the extent sufficient positive evidence becomes available, the Company may release all or a portion of its valuation allowance in one or more future periods. A release of the valuation allowance, if any, would result in the recognition of certain deferred tax assets and may result in a material income tax benefit for the period in which such release is recorded.
As of December 31, 2025, for tax return purposes, the Company had federal, state and foreign net operating loss carryforwards of approximately $0.4 million, $10 million and $1.4 billion, respectively. The federal, state and foreign net
operating loss carryforwards are subject to limitations under applicable tax law. State net operating loss carryforwards have varied expiration years beginning in 2032. Federal and foreign net operating losses carry forward indefinitely.
As of December 31, 2025, for tax return purposes, the Company had federal, state and foreign research and development tax credits of approximately $7 million, $38 million and $5 million, respectively, which can be carried forward as prescribed under applicable tax law. Federal and state tax credits will expire at various dates beginning in 2045 and 2035, respectively, unless utilized. Foreign research and development tax credits carry forward indefinitely.
As of December 31, 2025, the Company has not recorded a deferred tax liability for unremitted foreign earnings as the Company’s intention is to indefinitely reinvest these earnings outside the United States. Upon distribution of those earnings in the form of a dividend or otherwise, the Company would be subject to both state income taxes and withholding taxes payable to various foreign countries. The amounts of such tax liabilities that might be payable upon repatriation of foreign earnings are not material.
As of December 31, 2025, the Company had gross unrecognized tax benefits of approximately $116 million, $83 million of which is a reduction to deferred tax assets and the remaining $33 million which would affect the Company’s effective tax rate if recognized. As of December 31, 2024, the Company had gross unrecognized tax benefits of approximately $107 million, $73 million of which is a reduction to deferred tax assets and the remaining $34 million which would affect the Company’s effective tax rate if recognized.
The following table presents changes in gross unrecognized tax benefits (in thousands):
Year Ended December 31,
2025
2024
2023
Beginning balance$106,989 $97,703 $90,932 
Increases related to prior year tax positions3,158 881 229 
Decreases related to prior year tax positions(504)— — 
Increases related to current year tax positions5,923 8,405 6,601 
Settlements— — (59)
Expiration of statute of limitations— — — 
Ending balance$115,566 $106,989 $97,703 
Interest and penalties related to the Company’s unrecognized tax benefits accrued as of December 31, 2025 were not material.
The Company files U.S. federal, state and foreign tax returns. The Company is currently under examination by the Internal Revenue Service for the years ended December 31, 2015, 2016, 2017, 2018, 2019 and 2020. The Company is also currently under examination by various state and foreign jurisdictions.
The Company remains subject to examination for its federal and state tax returns for the periods 2015 through 2024, and 2020 through 2024, respectively. The majority of the Company’s foreign subsidiaries remain subject to examination by local taxing authorities for 2019 and subsequent years.
In 2021, the Organization for Economic Cooperation and Development (“OECD”) announced an Inclusive Framework on Base Erosion and Profit Shifting, including Pillar Two Model Rules defining the global minimum tax, which calls for the taxation of large multinational corporations at a minimum rate of 15%. Many non-U.S. tax jurisdictions have either recently enacted legislation to adopt certain components of the Pillar Two Model Rules in 2024 (including the European Union Member States) with the adoption of additional components in later years or announced their plans to enact legislation in future years. This legislation did not impact the Company’s provision for income taxes or effective tax rate in 2025. The Company continues to monitor for evolving tax legislation in the individual jurisdictions in which it operates and for changes to its operations that could be impacted by legislation.
On July 4, 2025, the United States enacted the One Big Beautiful Bill Act (the “OBBBA”), which changes or makes permanent certain tax laws for corporations, including provisions relating to domestic research and development costs, bonus depreciation and foreign derived intangible income. The primary impact to the Company is the option to immediately deduct research and development costs paid or incurred after December 31, 2024, for income tax purposes. In
addition, the OBBBA allows for the accelerated deduction of any remaining unamortized domestic research and development costs over a one-year or two-year period beginning after December 31, 2024, at the Company’s election. As a result, during the year ended December 31, 2025, the Company recognized $175 million relating to domestic research and development costs as income taxes receivable, presented in prepaid expenses and other current assets, with a corresponding reduction in deferred tax assets. The Company continues to monitor for changes in its operations that could be impacted by the legislation.

Historical Timeline

Fiscal YearFiled
2025Feb 27, 2026Showing above
2024Feb 21, 2025
2023Feb 15, 2024
2022Feb 15, 2023
2021Feb 16, 2022
2020Feb 19, 2021
2019Feb 28, 2020
2018Feb 22, 2019
2017Feb 28, 2018
2016Feb 16, 2017

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.