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Income Taxes
12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
Income (loss) before income taxes by geographic area is summarized in the table below.
 Years Ended December 31,
 202420232022
Domestic$(3,904)$1,499 $1,661 
Foreign(a)
25 29 30 
Total$(3,879)$1,528 $1,691 
(a)Inclusive of income (loss) before income taxes from Puerto Rico.
The benefit (provision) for income taxes consists of the following: 
 Years Ended December 31,
 202420232022
Current:
Federal$(9)$(7)$(6)
Foreign(6)(9)(9)
State(5)(2)
Total current(20)(18)(13)
Deferred:
Federal
— — 
Foreign(5)(8)(3)
Total deferred(4)(8)(3)
Total tax benefit (provision)$(24)$(26)$(16)
A reconciliation between the benefit (provision) for income taxes and the amount computed by applying the federal statutory income tax rate to the income (loss) before income taxes is as follows:
 Years Ended December 31,
 202420232022
Benefit (provision) for income taxes at statutory rate$815 $(321)$(355)
Tax adjustment related to REIT operations(822)313 349 
Valuation allowances(1)— (1)
State tax (provision) benefit, net of federal(5)(2)
Foreign tax(11)(16)(11)
Total$(24)$(26)$(16)
The components of the net deferred income tax assets and liabilities are as follows: 
 December 31,
 20242023
Deferred income tax liabilities:
Property and equipment$11 $10 
Deferred site rental receivables
Site rental contracts and tenant relationships, net
29 29 
Total deferred income tax liabilities47 48 
Deferred income tax assets:
Other intangible assets, net
29 29 
Net operating loss carryforwards(a)
Straight-line rent expense liability
Accrued liabilities
Other
Valuation allowances(3)(2)
Total deferred income tax assets, net43 47 
Net deferred income tax assets (liabilities)$(4)$(1)
(a)Balance results from the Company's foreign NOLs. Due to the Company's REIT status, no federal or state NOLs result in the Company recording a deferred income tax asset. See further discussion surrounding the Company's NOL balances below.
The Company operates as a REIT for U.S. federal income tax purposes.
The components of the net deferred income tax assets (liabilities) are as follows:
 December 31, 2024December 31, 2023
ClassificationGrossValuation AllowanceNetGrossValuation AllowanceNet
Federal$28 $(2)$26 $26 $(1)$25 
State— — 
Foreign(30)(1)(31)(26)(1)(27)
Total$(1)$(3)$(4)$$(2)$(1)
The Company recorded valuation allowances totaling $3 million and $2 million, as of December 31, 2024 and 2023 respectively, related to certain deferred tax assets as management believes that it is not "more likely than not" that the Company will realize the assets.
At December 31, 2024, the Company had U.S. federal and state NOLs of approximately $1.5 billion and $0.4 billion, respectively, which are available to offset future taxable income. These amounts include approximately $237 million of losses related to stock-based compensation. As footnoted above, the Company’s federal and state NOLs are valued at a tax rate of 0% for deferred income tax purposes due to the Company’s REIT status. As a result, any expirations of these NOLs will not have any impact on the Company’s Consolidated Balance Sheet or the Consolidated Statement of Operations and Comprehensive Income (Loss). The Company also has foreign NOLs of $3 million. If not utilized, the Company's U.S. federal NOLs expire starting in 2025 and ending in 2036, the remaining state NOLs expire starting in 2025 and ending in 2043, and the foreign NOLs start expiring in 2028 and ending in 2036. The federal NOLs potentially expiring in 2025 are $128 million, and the state NOLs potentially expiring in 2025 are $52 million. The utilization of the NOLs is subject to certain limitations. The Company's U.S. federal and state income tax returns generally remain open to examination by taxing authorities until three years after the applicable NOLs have been used or expired.
As of December 31, 2024, there were no unrecognized tax benefits that would impact the effective tax rate, if recognized.
From time to time, the Company is subject to examinations by various tax authorities in jurisdictions in which the Company has business operations. At this time, the Company is not subject to an Internal Revenue Service examination.
The Company regularly assesses the likelihood of additional assessments in each of the tax jurisdictions in which it has business operations. The Company has no uncertain tax positions as of December 31, 2024. Additionally, the Company does
not believe any such additional assessments arising from examinations or audits will have a material effect on the Company's financial statements.
As of December 31, 2024, the Company's deferred tax assets are included in "Other assets, net" and the Company's deferred tax liabilities are included in "Other long-term liabilities" on the Company's consolidated balance sheet.