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Income Taxes
 9 Months Ended
Sep. 30, 2023
Income Tax Disclosure [Abstract]  
INCOME TAXES INCOME TAXES
Our effective tax rate, exclusive of non-controlling interests, for the three and nine months ended September 30, 2023 was 20.8% and 24.4%, respectively. Our effective tax rate, exclusive of non-controlling interests, for the three and nine months ended September 30, 2022 was 17.9% and 21.8%, respectively. Our effective tax rate for the nine months ended September 30, 2023 reflected benefits of $20.6 million from tax settlements, $7.9 million from investments in solar energy assets qualifying for federal tax credits under Section 48 of the Internal Revenue Code and $6.8 million due to the realization of additional federal and state benefits as well as adjustments to deferred taxes due to the completion of our 2022 tax returns.
Our effective tax rate for the nine months ended September 30, 2022 reflected benefits of $60.2 million from investments in solar energy assets qualifying for tax credits under Section 48 of the Internal Revenue Code and $6.8 million due to the realization of additional federal and state benefits as well as adjustments to deferred taxes due to the completion of our 2021 tax returns.
For the nine months ended September 30, 2023 and 2022, net cash paid for income taxes was $137.9 million and $90.5 million, respectively.
We have deferred tax assets related to state net operating loss carryforwards. We provide a partial valuation allowance due to uncertainty surrounding the future utilization of these carryforwards in the taxing jurisdictions where the loss carryforwards exist. When determining the need for a valuation allowance, we consider all positive and negative evidence, including recent financial results, scheduled reversals of deferred tax liabilities, projected future taxable income and tax planning strategies. The realization of our deferred tax asset for state loss carryforwards ultimately depends upon the existence of sufficient taxable
income in the appropriate state taxing jurisdictions in future periods. The weight given to the positive and negative evidence is commensurate with the extent such evidence can be objectively verified. We continue to regularly monitor both positive and negative evidence in determining the ongoing need for a valuation allowance. As of September 30, 2023, the valuation allowance associated with our state loss carryforwards was approximately $44.1 million.
We are subject to income tax in the United States, as well as income tax in multiple state and foreign jurisdictions. Our compliance with income tax rules and regulations is periodically audited by taxing authorities. These authorities may challenge the positions taken in our tax filings. Thus, to provide for certain potential tax exposures, we maintain liabilities for uncertain tax positions for our estimate of the final outcome of these examinations. The federal statute of limitations applicable to our federal tax returns has passed for all years prior to 2015. For tax years 2015 to 2018 we have resolved all open issues with IRS Appeals while the applicable statutes of limitation will expire later in 2023 and early 2024. We are currently under state examination or administrative review in various state jurisdictions for tax years 2012 through 2021.
We believe the recorded liabilities for uncertain tax positions are adequate. However, a significant assessment against us in excess of the liabilities recorded could have a material adverse effect on our consolidated financial position, results of operations and cash flows. As of September 30, 2023, we are unable to estimate the resolution of our gross unrecognized benefits over the next 12 months.
We recognize interest and penalties as incurred within the provision for income taxes in the consolidated statement of income. As of September 30, 2023, we accrued a liability for penalties of $0.3 million and a liability for interest (including interest on penalties) of $12.4 million related to our uncertain tax positions.