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Income Taxes
 12 Months Ended
Dec. 31, 2023
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, 2023 and 2022 and 2021:
(in millions)202320222021
Income before income taxes:
Domestic$3,900.5 $3,291.7 $2,728.5 
Foreign253.1 198.6 645.1 
Total$4,153.6 $3,490.3 $3,373.6 
Income tax provision:
Current:
Federal$751.7 $620.5 $509.2 
State205.8 177.1 173.7 
Foreign44.9 24.9 19.0 
Total1,002.4 822.5 701.9 
Deferred:
Federal21.9 (16.3)(4.6)
State(33.8)(7.3)10.6 
Foreign(63.1)0.4 28.8 
Total(75.0)(23.2)34.8 
Total Income Tax Provision$927.4 $799.3 $736.7 
Reconciliation of the U.S. federal income tax rate (statutory tax rate) to the effective tax rate is as follows:
202320222021
Statutory tax rate21.0 %21.0 %21.0 %
State taxes, net of federal benefit3.3 3.9 4.3 
Gain on formation of OSTTRA— — (2.5)
Statutory rate change— — 1.1 
Foreign-derived intangible income deduction
(1.5)(1.5)(1.6)
Other, net(0.5)(0.5)(0.5)
Effective Tax Expense Benefit Rate22.3 %22.9 %21.8 %
In 2023 and 2022, the effective tax rates were higher than the statutory tax rate. The increases to the effective tax rate for the state taxes were partially offset by the foreign-derived intangible income (FDII) deduction.
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 FDII deduction.
At December 31, 2023 and 2022, deferred income tax assets (liabilities) consisted of the following: 
(in millions)20232022
Deferred Income Tax Assets:
Net operating losses$3.4 $3.7 
Accrued expenses, compensation, leases and other131.4 135.2 
Subtotal134.8 138.9 
Valuation allowance(0.4)(0.4)
Total deferred income tax assets134.4 138.5 
Deferred Income Tax Liabilities:
Purchased intangible assets(5,298.2)(5,358.8)
Other(115.4)(106.3)
Property(1.3)(30.4)
Total deferred income tax liabilities(5,414.9)(5,495.5)
Net Deferred Income Tax Liabilities$(5,280.5)$(5,357.0)
Reported as:
Net non-current deferred tax assets$47.2 $4.1 
Net non-current deferred tax liabilities(5,327.7)(5,361.1)
Net Deferred Income Tax Liabilities$(5,280.5)$(5,357.0)
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, 2023 and 2022, the company had domestic and foreign income tax loss carry forwards of $16.0 million and $17.6 million, respectively. These amounts primarily related to losses from the acquisition of NEX Group plc, the acquisition of Pivot, Inc., and losses incurred in the operation of various foreign entities. At December 31, 2023 and 2022, 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 $0.4 million was recorded at December 31, 2023 and 2022.
The following is a summary of the company’s unrecognized tax benefits at December 31, 2023, 2022 and 2021:
(in millions)202320222021
Gross unrecognized tax benefits$264.1 $280.3 $316.4 
Unrecognized tax benefits, net of tax impacts in other jurisdictions251.9 264.4 293.1 
Interest and penalties related to uncertain tax positions16.6 28.0 42.8 
Interest and penalties recognized on the consolidated statements of income(4.0)(3.8)5.3 
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)202320222021
Balance at January 1$280.3 $316.4 $328.2 
Additions based on tax positions related to the current year10.0 8.5 10.2 
Additions for tax positions of prior years4.3 2.7 9.6 
Reductions for tax positions of prior years(8.0)(9.5)(5.1)
Reductions resulting from the lapse of statutes of limitations(5.2)(5.5)(0.3)
Settlements with taxing authorities(17.3)(32.3)(26.2)
Balance at December 31$264.1 $280.3 $316.4 
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, 2023, substantially all federal and United Kingdom income tax matters had been concluded through 2013 and state income tax matters have been concluded through 2018.