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Income Taxes
 9 Months Ended
Sep. 30, 2025
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
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 has determined that the legislation did not have a material impact on its consolidated financial statements.
At September 30, 2025, the Company had gross uncertain tax benefits of $238.4 million, of which $193.1 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 positions38.5 
Reductions for tax positions(1.7)
Balance at September 30, 2025$238.4 
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 nine months ended September 30, 2025 and 2024 were not significant.
The effective tax rate for the three months ended September 30, 2025 was 17.1%, compared with 18.8% for the three months ended September 30, 2024. The lower effective tax rate in the third quarter of 2025 primarily reflects the remeasurement of deferred tax liabilities following the enactment of a lower corporate tax rate in Germany.