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INCOME TAXES
 12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
INCOME TAXES INCOME TAXES
Components of the Company’s income tax provision are as follows:
Year Ended December 31,
202420232022
Current:
Federal$280 $76 $106 
State and Local106 67 17 
Non-U.S.316 222 215 
Total current702 365 338 
Deferred:
Federal(21)(14)57 
State and Local(6)(4)10 
Non-U.S.(35)(20)(19)
Total deferred(62)(38)48 
Total provision for income taxes$640 $327 $386 
A reconciliation of the U.S. federal statutory tax rate to the Company’s ETR on income before provision for income taxes is as follows:
Year Ended December 31,
202420232022
U.S. statutory tax rate21.0 %21.0 %21.0 %
State and local taxes, net of federal tax benefit3.7 %2.5 %0.8 %
Foreign operations
(0.3)%0.4 %(0.2)%
Release of UTP reserves
(0.4)%(5.7)%— %
Other(0.3)%(1.3)%0.3 %
ETR
23.7 %16.9 %21.9 %
Income tax paid$613 $344 $488 
The decrease in the ETR in 2023 resulted primarily from the favorable resolution of uncertain tax positions in various U.S. and non-U.S. jurisdictions.
The source of income before provision for income taxes is as follows:
Year Ended December 31,
202420232022
U.S.$1,446 $892 $804 
Non-U.S.1,253 1,043 956 
Income before provision for income taxes$2,699 $1,935 $1,760 
The components of deferred tax assets and liabilities are as follows:
December 31,
20242023
Deferred tax assets:
Account receivable allowances$10 $9 
Accumulated depreciation and amortization9 19 
Stock-based compensation60 60 
Accrued compensation and benefits50 53 
Capitalized costs20 25 
Operating lease liabilities84 103 
Deferred revenue211 200 
Net operating loss58 38 
Restructuring6 7 
Uncertain tax positions33 29 
Self-insured related reserves7 6 
Interest expense carryforward20 8 
Other12 5 
Total deferred tax assets580 562 
Deferred tax liabilities:
Accumulated depreciation and amortization of intangible assets and capitalized software(522)(551)
ROU Assets(56)(67)
Capital gains(13)(20)
Self-insured related income(7)(6)
Deferred tax on unremitted foreign earnings(20)(14)
Gain on net investment hedges - OCI(82)(5)
Other(11)(19)
Total deferred tax liabilities(711)(682)
Net deferred tax liabilities(131)(120)
Valuation allowance(25)(24)
Total net deferred tax liabilities$(156)$(144)
On December 22, 2017, the Tax Act was signed into law, which resulted in significant changes to U.S. corporate tax laws. The Tax Act includes a mandatory one-time deemed repatriation tax (“transition tax”) on previously untaxed accumulated earnings of foreign subsidiaries and beginning in 2018 reduced the statutory federal corporate income tax rate from 35% to 21%. Accordingly, the Company determined the transition tax to be $236 million, with the remaining balance due of $12 million as of December 31, 2024.
As a result of the Tax Act, all previously net undistributed foreign earnings have now been subject to U.S. tax. The Company regularly evaluates which entities it will indefinitely reinvest earnings. The Company has provided deferred taxes for those entities whose earnings are not considered indefinitely reinvested.
The Company’s annual tax expense for the year ended December 31, 2024 includes excess tax benefits from stock-based compensation of $27 million, the favorable resolution of certain U.S. and non-U.S. UTPs of $11 million, and other net decreases to tax positions of $2 million.
The Company had valuation allowances of $25 million and $24 million at December 31, 2024 and 2023, respectively, related to foreign net operating losses for which realization is uncertain.
A reconciliation of the beginning and ending amount of UTPs is as follows:
Year Ended December 31,
202420232022
Balance as of January 1$196 $322 $388 
Additions for tax positions related to the current year33 21 12 
Additions for tax positions of prior years11 3 12 
Reductions for tax positions of prior years(11)(17)(27)
Settlements with taxing authorities(3)(108)(30)
Lapse of statute of limitations(15)(25)(33)
Balance as of December 31$211 $196 $322 
Moody’s Corporation and subsidiaries are subject to U.S. federal income tax as well as income tax in various state, local and multiple foreign jurisdictions. The Company’s U.S. federal income tax returns for 2021 through 2023 remain open to examination. The Company’s New York City tax returns for 2018 through 2022 are currently under examination and 2023 is open for examination. The Company’s U.K. tax returns from 2017 to 2023 remain open to examination.
As of December 31, 2024, the Company had $211 million of UTPs. Given the number of years and nature of matters that remain subject to examination in various tax jurisdictions both in the U.S. and internationally, the Company is unable to estimate a range of possible changes to its UTPs for 2025. It is also possible that new issues might be raised by tax authorities which might necessitate increases to the balance of UTPs. As the Company is unable to predict the timing of conclusion of these audits, the Company is unable to estimate the amount of changes to the balance of UTPs at this time. However, the Company believes that it has adequately provided for its financial exposure relating to all open tax years, by tax jurisdiction, in accordance with ASC Topic 740.
The Company classifies interest related to UTPs in interest expense in its consolidated statements of operations. Penalties, if incurred, are recognized in other non-operating (expense) income, net. Refer to Note 16 for disclosure of interest (expense) income relating to UTPs and other tax-related liabilities. As of December 31, 2024, 2023 and 2022 the amount of accrued interest recorded in the Company’s consolidated balance sheets related to UTPs was $47 million, $36 million and $47 million, respectively.
In August 2022, the U.S. Congress passed the Inflation Reduction Act, which included a corporate minimum tax on book earnings of 15%, an excise tax on corporate share repurchases of 1%, and certain climate change and energy tax credit incentives. The adoption of a corporate minimum tax of 15% did not have a significant impact on Moody’s ETR. The excise tax of 1% on corporate share buybacks is recorded to shareholders' equity and does not have an impact on the Company’s ETR.
Effective in 2024, multiple foreign jurisdictions in which the Company operates have enacted legislation to adopt a minimum tax rate described in the Global Anti-Base Erosion tax model rules (referred to as GloBE or Pillar II) issued by the OECD. A minimum ETR of 15% would apply to multinational companies with consolidated revenue above €750 million. Under the GloBE rules, a company would be required to determine a combined ETR for all entities located in a jurisdiction. If the jurisdictional tax rate is less than 15%, an additional tax generally will be due to bring the jurisdictional effective tax rate up to 15%. As of December 31, 2024, the Pillar II minimum tax did not have a material impact on the Company's full year results of operations or financial position.