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Income Taxes
 12 Months Ended
Dec. 31, 2024
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, 2024, 2023 and 2022:
(in millions)202420232022
Income before income taxes:
Domestic$4,305.9 $3,900.5 $3,291.7 
Foreign235.5 253.1 198.6 
Total$4,541.4 $4,153.6 $3,490.3 
Income tax provision:
Current:
Federal$776.9 $751.7 $620.5 
State252.8 205.8 177.1 
Foreign52.3 44.9 24.9 
Total1,082.0 1,002.4 822.5 
Deferred:
Federal(49.6)21.9 (16.3)
State(17.0)(33.8)(7.3)
Foreign0.2 (63.1)0.4 
Total(66.4)(75.0)(23.2)
Total Income Tax Provision$1,015.6 $927.4 $799.3 
Reconciliation of the U.S. federal income tax rate (statutory tax rate) to the effective tax rate is as follows:
202420232022
Statutory tax rate21.0 %21.0 %21.0 %
State taxes, net of federal benefit4.1 3.3 3.9 
Foreign-derived intangible income deduction
(1.7)(1.5)(1.5)
Other, net(1.0)(0.5)(0.5)
Effective Tax Expense Benefit Rate22.4 %22.3 %22.9 %
In 2024, 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.
At December 31, 2024 and 2023, deferred income tax assets (liabilities) consisted of the following: 
(in millions)20242023
Deferred Income Tax Assets:
Net operating losses$5.3 $3.4 
Property12.8 — 
Accrued expenses, compensation, leases and other123.9 131.4 
Subtotal142.0 134.8 
Valuation allowance— (0.4)
Total deferred income tax assets142.0 134.4 
Deferred Income Tax Liabilities:
Purchased intangible assets(5,240.6)(5,298.2)
Other(114.1)(115.4)
Property— (1.3)
Total deferred income tax liabilities(5,354.7)(5,414.9)
Net Deferred Income Tax Liabilities$(5,212.7)$(5,280.5)
Reported as:
Net non-current deferred tax assets$34.1 $47.2 
Net non-current deferred tax liabilities(5,246.8)(5,327.7)
Net Deferred Income Tax Liabilities$(5,212.7)$(5,280.5)
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, 2024, the company had domestic income tax loss carryforwards of $25.1 million of which $22.1 million will expire between 2030 and 2036 and $3.0 million can be carried forward indefinitely. These amounts primarily relate to losses from the acquisition of NEX Group plc and the acquisition of Pivot, Inc. No valuation allowance was recorded at December 31, 2024 and a valuation allowance of $0.4 million was recorded at December 31, 2023.
The following is a summary of the company’s unrecognized tax benefits at December 31, 2024, 2023 and 2022:
(in millions)202420232022
Gross unrecognized tax benefits$251.6 $264.1 $280.3 
Unrecognized tax benefits, net of tax impacts in other jurisdictions238.1 251.9 264.4 
Interest and penalties related to uncertain tax positions18.8 16.6 28.0 
Interest and penalties recognized on the consolidated statements of income2.1 (4.0)(3.8)
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)202420232022
Balance at January 1$264.1 $280.3 $316.4 
Additions based on tax positions related to the current year12.0 10.0 8.5 
Additions for tax positions of prior years3.9 4.3 2.7 
Reductions for tax positions of prior years(17.7)(8.0)(9.5)
Reductions resulting from the lapse of statutes of limitations(5.6)(5.2)(5.5)
Settlements with taxing authorities(5.1)(17.3)(32.3)
Balance at December 31$251.6 $264.1 $280.3 
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, 2024, substantially all federal income tax matters have been concluded through 2016 other than the Section 199 deduction. On April 15, 2024, the company filed a court case with the U.S. court of Federal Claims
related to the Section 199 deduction. All United Kingdom income tax matters have been concluded through 2017, and substantially all state income tax matters have been concluded through 2019.