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Income Taxes | 12 Months Ended
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Dec. 31, 2024
Income Tax Disclosure [Abstract] |
Income Taxes | Inco me Tax es Income before the p rovision for income taxes is attributable to the following jurisdictions for years ended December 31 (in thousands):
|  | 2024 |  | 2023 |  | 2022
United States |  | $278,330 |  | $322,856 |  | $506,214
Foreign |  | 1,106,783 |  | 1,002,149 |  | 769,446
Total |  | $1,385,113 |  | $1,325,005 |  | $1,275,660
The provision for income taxes for the years ended December 31 consists of the following (in thousands):
|  | 2024 |  | 2023 |  | 2022
Current: |  |  |  |  |  |
Federal |  | $168,982 |  | $155,647 |  | $166,172
State |  | 7,528 |  | 25,614 |  | 34,947
Foreign |  | 269,588 |  | 208,532 |  | 153,388
Total current |  | 446,098 |  | 389,793 |  | 354,507
Deferred: |  |  |  |  |  |
Federal |  | (62,190) |  | (46,676) |  | (36,613)
State |  | (19,080) |  | (8,088) |  | (6,066)
Foreign |  | 16,553 |  | 8,086 |  | 9,505
Total deferred |  | (64,717) |  | (46,678) |  | (33,174)
Total provision |  | $381,381 |  | $343,115 |  | $321,333
The provision for income taxes differs from amounts computed by applying the U.S. federal tax rate of 21% for 2024, 2023 and 2022, respectively, to income before income taxes for the years ended December 31, 2024, 2023 and 2022 due to the following (in thousands, except percentages):
|  | 2024 |  | 2023 |  | 2022
Computed “expected” tax expense |  | $290,877 |  | 21.0% |  | $278,251 |  | 21.0% |  | $267,889 |  | 21.0%
Changes resulting from: |  |  |  |  |  |  |  |  |  |  |  |
Change in valuation allowance |  | (64,289) | 1 | (4.6) |  | 22,447 |  | 1.7 |  | 22,399 |  | 1.8
Foreign tax credits |  | 1,309 | 1 | 0.1 |  | (98,641) |  | (7.4) |  | (73,974) |  | (5.8)
Foreign income tax differential |  | 31,743 |  | 2.3 |  | 14,949 |  | 1.1 |  | 566 |  | —
State taxes net of federal benefits |  | (9,047) |  | (0.7) |  | 13,857 |  | 1.0 |  | 12,745 |  | 1.0
Increase in tax expense due to uncertain tax positions |  | 38,395 |  | 2.8 |  | 14,146 |  | 1.1 |  | 8,257 |  | 0.6
Foreign withholding tax |  | 30,785 |  | 2.2 |  | 24,331 |  | 1.8 |  | 13,547 |  | 1.1
Stock-based compensation |  | (29,582) |  | (2.1) |  | 7,980 |  | 0.6 |  | (1,881) |  | (0.1)
Sub-part F Income/GILTI |  | 87,252 |  | 6.3 |  | 94,594 |  | 7.1 |  | 79,420 |  | 6.2
Brazil tourism tax benefit |  | — |  | — |  | (16,311) |  | (1.2) |  | (13,810) |  | (1.1)
Interest on net equity deduction |  | (20,757) |  | (1.5) |  | (15,051) |  | (1.1) |  | — |  | —
Impairment of goodwill |  | 18,900 |  | 1.4 |  | — |  | — |  | — |  | —
Other |  | 5,795 |  | 0.4 |  | 2,563 |  | 0.2 |  | 6,175 |  | 0.5
Provision for income taxes |  | $381,381 |  | 27.5% |  | $343,115 |  | 25.9% |  | $321,333 |  | 25.2%
1 The valuation allowance decrease was primarily due to the release of a deferred tax asset of $84.5 million and a corresponding valuation allowance reduction of $84.5 million related to income tax credits in a non-U.S. jurisdiction.
The tax effects of temporary differences that give rise to significant portions of the deferred tax assets and liabilities at December 31 are as follows (in thousands):
|  | 2024 |  | 2023
Deferred tax assets: |  |  |  |
Accounts receivable, principally due to the allowance for credit losses |  | $16,756 |  | $20,110
Accrued expenses not currently deductible for tax |  | 13,263 |  | 12,922
Lease deferral |  | 15,423 |  | 15,767
Interest rate swap |  | — |  | 11,994
Stock-based compensation |  | 29,425 |  | 47,537
Income tax credits |  | — |  | 84,505
Net operating loss carry forwards |  | 159,603 |  | 134,911
Accrued escheat |  | 3,897 |  | 3,456
Other |  | 110,804 |  | 55,466
Deferred tax assets before valuation allowance |  | 349,171 |  | 386,668
Valuation allowance |  | (113,223) |  | (165,982)
Deferred tax assets, net |  | 235,948 |  | 220,686
Deferred tax liabilities: |  |  |  |
Intangibles—including goodwill |  | (548,802) |  | (536,561)
Basis difference in investment in subsidiaries |  | (42,206) |  | (43,821)
Interest rate swap |  | (8,695) |  | —
Lease deferral |  | (13,536) |  | (13,589)
Accrued expense liability |  | (722) |  | (718)
Prepaid expenses |  | (1,172) |  | (1,805)
Withholding taxes |  | (18,472) |  | (26,407)
Property and equipment and other |  | (38,646) |  | (66,617)
Deferred tax liabilities |  | (672,251) |  | (689,518)
Net deferred tax liabilities |  | $(436,303) |  | $(468,832)
The Company’s deferred tax balances are classified in its balance sheets as of December 31 as follows (in thousands):
|  | 2024 |  | 2023
Long term deferred tax assets and liabilities: |  |  |  |
Long term deferred tax assets |  | $2,873 |  | $1,400
Long term deferred tax liabilities |  | (439,176) |  | (470,232)
Net deferred tax liabilities |  | $(436,303) |  | $(468,832)
The valuation allowances relate to foreign net operating loss carryforwards, state net operating loss carryforwards and state 163(j) limitation on business interest carryforward. The net change in the total valuation allowance for the year ended December 31, 2024 was a decrease of $52.8 million. The valuation allowance decrease was primarily due to the release of a foreign tax credit deferred tax asset where a valuation allowance was previously recorded as well as an increase in foreign net operating losses where significant negative evidence on future utilization was considered. As of December 31, 2024, the Company had a net operating loss carryforward for state income tax purposes of approximately $55.7 million that is available to offset future state tax expense, either indefinitely or in some cases subject to expiration in 15 or 20 years. Additionally, the Company had $103.9 million net operating loss carryforwards for foreign income tax purposes that are available to offset future foreign tax expense. Most foreign net operating loss carryforwards will not expire in future years. The Company has provided a valuation allowance against $101.3 million of its deferred tax asset related to the net operating losses as it does not anticipate utilizing the losses in the foreseeable future. During 2024 and 2023, the Company had recorded accrued interest and penalties related to the unrecognized tax benefits of $6.1 million and $8.1 million, respectively. Accumulated interest and penalties were $36.8 million and $30.7 million on the Consolidated Balance Sheets at December 31, 2024 and 2023, respectively. In accordance with the Company's accounting policy, interest and penalties related to unrecognized tax benefits are included as a component of income tax expense. A reconciliation of the beginning and ending balances of the total amounts of gross unrecognized tax benefits excluding interest and penalties for the years ended December 31, 2024, 2023 and 2022 is as follows (in thousands):
Unrecognized tax benefits at December 31, 2021 |  | $47,021
Additions based on tax positions related to the current year |  | 7,752
Additions based on tax positions related to the prior year |  | 200
Deductions based on settlement of prior year tax positions |  | (1,550)
Addition for cumulative federal benefit of state tax deductions |  | 7,281
Change due to OCI |  | (35)
Unrecognized tax benefits at December 31, 2022 |  | 60,669
Additions based on tax provisions related to the current year |  | 8,821
Deductions based on tax positions related to the prior year |  | (1,913)
Deductions based on settlements of prior year tax positions |  | (104)
Deductions based on expiration of prior year tax positions |  | (4,235)
Change due to OCI |  | (132)
Unrecognized tax benefits at December 31, 2023 |  | 63,106
Additions based on tax provisions related to the current year |  | 21,689
Additions and deductions based on tax positions related to the prior year |  | 14,206
Deductions based on settlements of prior year tax positions |  | (178)
Deductions based on expiration of prior year tax positions |  | (3,362)
Change due to OCI |  | (1)
Unrecognized tax benefits at December 31, 2024 |  | $95,460
In prior years, the Company included federal benefits of state tax deductions related to unrecognized tax benefits in its tabular reconciliation above. A cumulative adjustment was made in 2022 to remove these amounts from the above tabular disclosure. As of December 31, 2024, the Company had total unrecognized tax benefit s of $95.5 million all of whic h, if recognized, would affect its effective tax rate. It is not anticipated that there are any unrecognized tax benefits that will significantly increase or decrease within the next twelve months. The Company files numerous consolidated and separate income tax returns in the U.S. federal jurisdiction and various state and foreign jurisdictions. The statute of limitations for the Company’s U.S. federal income tax returns has expired for years prior to 2015. With few exceptions, the Company is no longer subject to U.S. federal, state and local, or non-U.S. income tax examinations by tax authorities for years before 2015. The Organization for Economic Co-operation and Development (OECD), continues to put forth various initiatives, including Pillar Two rules which introduce a global minimum tax at a rate of 15%. European Union member states agreed to implement the OECD’s Pillar Two rules with effective dates of January 1, 2024 and January 1, 2025 for different aspects of the directive, and most have already enacted legislation. A number of other countries are also implementing similar legislation. As of December 31, 2024, based on the countries in which we do business that have enacted legislation effective January 1, 2024, the impact of these rules to our financial statements was not material. This may change as other countries enact similar legislation and further guidance is released. We are currently evaluating the impact of the enacted legislation effective January 1, 2025 to our financial statements and continue to closely monitor regulatory developments to assess potential impacts.

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