U-Haul Holding Co /NV/ Income Taxes Disclosure

Note 15. Provision for Taxes

The NOL, interest and credit carry-forwards in the above table are primarily attributable to state NOLs. As of March 31, 2025 and 2024, we had state NOLs of $816.8 million and $628.9 million, respectively, that will expire between fiscal 2026 and 2045 for most jurisdictions, if not utilized.

On March 3, 2021, the IRS notified us that our federal income tax returns for the tax years March 31, 2014, 2015, 2016, 2018 and 2019 were selected for examination. The examination eventually expanded to include all years March 31, 2012 through March 31, 2021. The examination was completed and report finalized in March 2024. As a result, we are owed $129 million which is reflected in prepaid expense, plus interest of $19.0 million, which is reflected in trade receivables and reinsurance recoverables, net. The refund is currently under review by the Joint Committee on Taxation.

No additional income taxes have been provided for any remaining undistributed foreign earnings or any additional outside basis difference inherent in these entities, as these amounts continue to be indefinitely reinvested in foreign operations. Determining the amount of unrecognized deferred tax liability related to any remaining undistributed foreign earnings and additional outside basis difference in these entities (i.e., basis difference in excess of that subject to the one-time transition tax) is not practicable.

We account for uncertainty in income taxes by recognizing the tax benefit or expense from an uncertain tax position only if it is more likely than not that the tax position will be sustained upon examination by the taxing authorities, based on the technical merits of the position. The Company measures the tax benefits and expenses recognized in the consolidated financial statements from such a position based on the largest benefit that has a greater than 50% likelihood of being realized upon ultimate resolution.

A reconciliation of the total amounts of unrecognized tax benefits at the beginning and end of the period are as follows:

Included in the balance of unrecognized tax benefits as of March 31, 2025 and March 31, 2024 are $66.0 million and $64.8 million, respectively, of tax benefits that, if recognized, would affect the effective tax rate.

We recognize interest related to unrecognized tax benefits as interest expense and penalties as income tax expenses. As of March 31, 2025 and 2024, the amount of interest accrued on unrecognized tax benefits was $13.3 million and $9.6 million, respectively, net of tax. During the current year, we recorded a benefit from interest in the amount of $3.7 million, net of tax. At March 31, 2025 and 2024, the amount of penalties accrued on unrecognized tax benefits was $21.8 million and $20.2 million. During the current year, we recorded expense from penalties in the amount of $1.6 million. We do not expect the total amount of unrecognized tax benefits to significantly increase or decrease within 12 months of the reporting date.

We file income tax returns in the U.S. federal jurisdiction, and various states and Canadian jurisdictions. While the Company has ongoing audits in various state jurisdictions, there have been no proposed or anticipated adjustments that would materially impact the consolidated financial statements. Our tax years remain open for examination by federal authorities for three years, state authorities for three to four years and Canadian authorities for four years.

The Canadian government has issued draft Pillar Two legislation (Global Minimum Tax Act), on June 20, 2024, that includes the Income Inclusion Rule and Qualified Domestic Minimum Top-Up Tax. The Canadian legislation went into effect for our fiscal year beginning April 1, 2024. We have performed an assessment of the potential exposure to Pillar Two income taxes. Based on the assessment performed, the Pillar Two effective tax rates in all jurisdictions in which we operate are above the 15% minimum tax rate. We will continue to evaluate the legislation but do not expect the rules to have an impact on the income tax provision or cash taxes.