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Income Taxes
6 Months Ended
Jun. 30, 2025
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
At June 30, 2025, the Company had gross uncertain tax benefits of $223.1 million, of which $178.5 million, if recognized, would impact the effective tax rate.
The following is a reconciliation of the liability for uncertain tax positions (in millions):
Balance at December 31, 2024$201.6 
Additions for tax positions23.2 
Reductions for tax positions(1.7)
Balance at June 30, 2025$223.1 
The additions above primarily reflect the tax positions for foreign tax planning initiatives. The Company recognizes interest and penalties accrued related to uncertain tax positions in income tax expense. The amounts recognized in income tax expense for interest and penalties during the three and six months ended June 30, 2025 and 2024 were not significant.
The effective tax rate for the three months ended June 30, 2025 and 2024 was 19.0%.
Subsequent Event
On July 4, 2025, the President signed into law the One Big Beautiful Bill Act (“OBBBA”), enacting permanent extensions of most expiring Tax Cuts and Jobs Act provisions and international tax changes, including modifications to bonus depreciation, R&D expensing, and interest expense limitations. The Company is currently evaluating the potential impacts of the OBBBA.