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Income Taxes
6 Months Ended
Jun. 30, 2023
Income Tax Disclosure [Abstract]  
Income Taxes
5.
Income Taxes

The Company recorded income tax expense of $56.3 million, or 24.3% of pre-tax income, for the three months ended June 30, 2023, compared to $15.4 million, or 31.2% of pre-tax income, for the three months ended June 30, 2022. Results for the three months ended June 30, 2023 were unfavorably impacted by $1.2 million of net discrete tax items. Results for the three months ended June 30, 2022 were unfavorably impacted by $1.5 million of net discrete items.

The Company recorded income tax expense of $90.5 million, or 25.1% of pre-tax income, for the six months ended June 30, 2023, compared to $36.2 million, or 51.3% of pre-tax income, for the six months ended June 30, 2022. Results for the six months ended June 30, 2023 were unfavorably impacted by $4.2 million of net discrete tax items, including charges of $2.5 million related to a valuation allowance recorded with respect to unrealizable foreign tax credits and $1.7 million related to a valuation allowance recorded with respect to a deferred tax asset on marketable securities. Results for the six months ended June 30, 2022 were unfavorably impacted by $16.9 million of net discrete tax items, including a charge of $18.1 million related to taxes on previous income as the Company revised its interpretation of certain foreign anti-hybrid tax legislation based upon comments from the corresponding tax authorities.

The Company’s liability for gross unrecognized tax benefits, excluding related interest and penalties, was $92.5 million and $98.8 million as of June 30, 2023 and December 31, 2022, respectively. As of June 30, 2023, net unrecognized tax benefits, excluding interest and penalties, of $51.9 million would affect the Company’s net income if recognized.

The Company recognizes accrued interest and penalties, if any, related to unrecognized tax benefits in the “Provision for income taxes” in the Condensed Consolidated Statements of Income. During the six months ended June 30, 2023 and 2022, the Company recognized expense of $0.9 million and $0.7 million, respectively, related to interest and penalties. At June 30, 2023, the Company had accruals for the payment of interest and penalties of $5.7 million. During the next twelve months, it is reasonably possible that federal, state and foreign tax audit resolutions could reduce net unrecognized tax benefits by approximately $1.4 million because the Company’s tax positions are sustained on audit, the Company agrees to their disallowance or the statutes of limitations close.