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INCOME TAXES
6 Months Ended
Jun. 30, 2021
INCOME TAXES  
INCOME TAXES

19.  INCOME TAXES

The Company records income tax expense during interim periods based on the best estimate of the full year’s tax rate as adjusted for discrete items, if any, that are taken into account in the relevant interim period. Each quarter, the Company updates its estimate of the annual effective tax rate and any change in the estimated rate is recorded on a cumulative basis.

The effective tax rate from continuing operations was 41.1% and 27.5% for the three months ended June 30, 2021 and 2020, respectively, and 34.8% and 27.6% for the six months ended June 30, 2021 and 2020, respectively. The higher effective tax rate in 2021 is primarily due to the remeasurement of UK deferred tax liabilities following the UK tax rate increase from 19% to 25% enacted during the second quarter and effective April 1, 2023.

The Company petitioned the U.S. Tax Court on January 13, 2017, May 7, 2018 and November 29, 2018 for a redetermination of IRS notices of deficiency for Cboe and certain of its subsidiaries for tax years 2011 through 2015 related to its Section 199 claims. The Company also filed a complaint on October 5, 2018 with the Court of Federal Claims for a refund of Section 199 claims related to tax years 2008 through 2010. The first case in the docket scheduled for trial relates to certain subsidiaries for tax years 2011, 2012 and 2013. The trial was held remotely from May 24, 2021 until June 1, 2021. Post-trial briefing in that case is scheduled to conclude on October 18, 2021. Although there can be no assurances, the Company continues to believe, based on its current assessment of the Section 199 claims, that the reasonably expected aggregate amount of any additional liabilities that may result from these cases, if any, will not have a material adverse effect on the financial position, results of operations, or cash flows of the Company. As of June 30, 2021, the Company has not resolved these matters, and proceedings continue in U.S. Tax Court and the Court of Federal Claims.