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Income Taxes
 12 Months Ended
Dec. 31, 2021
Income Tax Disclosure [Abstract]  
Income Taxes INCOME TAXES
The company is subject to regulation under a wide variety of U.S., federal, state and foreign tax laws and regulations. Income before income taxes and the income tax provision consisted of the following for the years ended December 31, 2021, 2020 and 2019:
(in millions)202120202019
Income before income taxes:
Domestic$2,728.5 $2,640.7 $2,650.2 
Foreign645.1 81.4 39.4 
Total$3,373.6 $2,722.1 $2,689.6 
Income tax provision:
Current:
Federal$509.2 $488.4 $419.5 
State173.7 140.1 139.2 
Foreign19.0 28.8 18.8 
Total701.9 657.3 577.5 
Deferred:
Federal(4.6)2.3 (6.7)
State10.6 (36.8)28.0 
Foreign28.8 (7.1)(25.0)
Total34.8 (41.6)(3.7)
Total Income Tax Provision$736.7 $615.7 $573.8 
Reconciliation of the U.S. federal income tax rate (statutory tax rate) to the effective tax rate is as follows:
202120202019
Statutory tax rate21.0 %21.0 %21.0 %
State taxes, net of federal benefit4.0 4.0 4.1 
Gain on formation of OSTTRA(2.5)— — 
Statutory rate change1.1 — — 
Impact of revised state and local apportionment estimates0.3 (1.0)0.8 
Foreign-derived intangible income deduction
(1.6)(2.0)(3.8)
Other, net(0.5)0.6 (0.8)
Effective Tax Expense Benefit Rate21.8 %22.6 %21.3 %
In 2021, the effective tax rate was higher than the statutory tax rate. The increase to the effective tax rate for the state taxes and the impact of the statutory rate change in the United Kingdom was partially offset by the non-taxable gain on the formation of OSTTRA and the foreign-derived intangible income (FDII) deduction.
In 2020, the effective tax rate was higher than the statutory tax rate. The increase to the effective tax rate for the state taxes was partially offset by the FDII deduction.
In 2019, the effective tax rate was slightly higher than the statutory tax rate. The increase to the effective tax rate for the state taxes was partially offset by the FDII deduction. Proposed FDII deduction regulations were released in 2019 and as a result, management revised the income tax calculations to reflect the proposed guidance. The benefit recognized in 2019 includes estimates for the deduction for 2018 and 2019.
At December 31, 2021 and 2020, deferred income tax assets (liabilities) consisted of the following: 
(in millions)20212020
Deferred Income Tax Assets:
Net operating losses$21.0 $36.8 
Accrued expenses, compensation, leases and other163.1 165.2 
Subtotal184.1 202.0 
Valuation allowance(0.6)(11.3)
Total deferred income tax assets183.5 190.7 
Deferred Income Tax Liabilities:
Purchased intangible assets(5,405.8)(5,614.9)
Other(123.4)(106.1)
Property(40.5)(45.7)
Total deferred income tax liabilities(5,569.7)(5,766.7)
Net Deferred Income Tax Liabilities$(5,386.2)$(5,576.0)
Reported as:
Net non-current deferred tax assets$4.2 $31.0 
Net non-current deferred tax liabilities(5,390.4)(5,607.0)
Net Deferred Income Tax Liabilities$(5,386.2)$(5,576.0)
A valuation allowance is recorded when it is more-likely-than-not that some portion or all of the deferred income tax assets may not be realized. The ultimate realization of the deferred income tax assets depends on the ability to generate sufficient taxable income of the appropriate character in the future and in the appropriate taxing jurisdictions.
At December 31, 2021 and 2020, the company had domestic and foreign income tax loss carry forwards of $88.6 million and $190.2 million, respectively. These amounts primarily related to losses from the acquisition of NEX Group plc, the acquisitions of Swapstream Limited and its affiliates, the acquisition of Pivot, Inc., losses incurred in the operation of various foreign entities. At December 31, 2021 and 2020, the company determined that it was not more-likely-than-not that certain foreign deferred income tax assets will be fully realized.
As a result, valuation allowances of $0.6 million and $11.3 million were recorded at December 31, 2021 and 2020, respectively.
The following is a summary of the company’s unrecognized tax benefits at December 31, 2021, 2020 and 2019:
(in millions)202120202019
Gross unrecognized tax benefits$316.4 $328.2 $388.5 
Unrecognized tax benefits, net of tax impacts in other jurisdictions293.1 302.4 359.6 
Interest and penalties related to uncertain tax positions42.8 43.6 53.3 
Interest and penalties recognized on the consolidated statements of income5.3 7.7 (1.5)
The company does not believe it is reasonably possible that within the next twelve months, unrecognized tax benefits will change by a significant amount.
A reconciliation of the beginning and ending amounts of gross unrecognized tax benefits is as follows:
(in millions)202120202019
Balance at January 1$328.2 $388.5 $396.2 
Additions based on tax positions related to the current year10.2 20.2 30.3 
Additions for tax positions of prior years9.6 3.2 4.7 
Reductions for tax positions of prior years(5.1)(10.8)(8.8)
Reductions resulting from the lapse of statutes of limitations(0.3)— (1.7)
Settlements with taxing authorities(26.2)(72.9)(32.2)
Balance at December 31$316.4 $328.2 $388.5 
The company is subject to U.S. federal income tax as well as income taxes in Illinois and multiple other state, local and foreign jurisdictions.  As of December 31, 2021, substantially all federal and state income tax matters had been concluded through 2007 and 2006, respectively, and through 2013 for the United Kingdom.