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INCOME TAXES
 9 Months Ended
Sep. 30, 2025
Income Tax Disclosure [Abstract]  
INCOME TAXES INCOME TAXES
The Company provides for income taxes at the end of each interim period based on the estimated effective tax rate (“ETR”) for the full fiscal year. Cumulative adjustments to the Company’s estimate are recorded in the interim period in which a change in the estimated annual ETR is determined. Under the provisions of the Internal Revenue Code of 1986, as amended, the Company may deduct earnings distributed to stockholders against the income generated by its real estate investment trust (“REIT”) operations. The Company continues to be subject to income taxes on the income of its domestic taxable REIT subsidiaries and income taxes in foreign jurisdictions where it conducts operations.
On July 4, 2025, the One Big Beautiful Bill (“OBBB Act”), which includes a broad range of tax reform provisions, was signed into law in the United States. The Company does not expect the OBBB Act will have a material impact on its estimated annual effective tax rate in 2025.
The Company provides valuation allowances if, based on the available evidence, it is more likely than not that some or all of the deferred tax assets will not be realized. Management assesses the available evidence to estimate if sufficient future taxable income will be generated to use the existing deferred tax assets. Valuation allowances may be reversed if, based on changes in facts and circumstances, the net deferred tax assets have been determined to be realizable.
The decrease in the income tax provision during the three months ended September 30, 2025 was primarily attributable to the benefit from the application of a tax law change in Germany and a decrease in tax expense attributable to
unrealized gains from equity securities in the United States. The decrease in the income tax provision during the nine months ended September 30, 2025 was primarily attributable to the benefit from the application of a tax law change in Germany, partially offset by increased earnings in certain foreign jurisdictions, taxes incurred as a result of the sale of South Africa Fiber, and additions to reserves for uncertain tax positions.
As of September 30, 2025 and December 31, 2024, the total unrecognized tax benefits that would impact the ETR, if recognized, were approximately $131.4 million and $101.3 million, respectively. The amount of unrecognized tax benefits during the three and nine months ended September 30, 2025 includes (i) additions to the Company’s existing tax positions of $18.1 million and $40.1 million, respectively, (ii) additions due to foreign currency exchange rate fluctuations of $1.9 million and $9.9 million, respectively, (iii) reductions due to the expiration of statutes of limitation of $0.8 million and $14.1 million, respectively, and (iv) reductions to the Company’s prior year tax positions and settlements of $5.8 million during the nine months ended September 30, 2025. Unrecognized tax benefits are expected to change over the next 12 months if certain tax matters ultimately settle with the applicable taxing jurisdiction during this time frame, as described in note 12 to the Company’s consolidated financial statements included in the 2024 Form 10-K. The impact of the amount of these changes to previously recorded uncertain tax positions could range from zero to $16.0 million.
The Company recorded the following penalties and income tax-related interest expense during the three and nine months ended September 30, 2025 and 2024:
Three Months Ended September 30,Nine Months Ended September 30,
2025202420252024
Penalties and income tax-related interest expense$11.5 $12.4 $22.8 $21.9 
As of September 30, 2025 and December 31, 2024, the total amount of accrued income tax related interest and penalties included in the consolidated balance sheets were $81.2 million and $58.5 million, respectively.