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Income Taxes
9 Months Ended
Sep. 30, 2022
Income Tax Disclosure [Abstract]  
Income Taxes
12. Income Taxes
The Company’s provision (benefit) for income taxes was $76.2 million and $153.9 million for the three months ended September 30, 2022 and 2021, respectively, and $274.9 million and $733.5 million for the nine months ended September 30, 2022 and 2021, respectively. The Company’s effective tax rate was approximately 21% and 22% for the three months ended September 30, 2022 and 2021, respectively, and 20% and 24% for the nine months ended September 30, 2022 and 2021, respectively. The effective tax rate for the nine months ended September 30, 2022 and 2021 is primarily comprised of the 21% U.S. federal corporate income tax rate plus U.S. state and foreign corporate income taxes and tax deductions resulting from the vesting of restricted stock units during the period, the impact of which was greater during the nine months ended September 30, 2022 due to a larger number of vested units. The effective tax rate for the nine months ended September 30, 2022 also reflects a deferred tax benefit resulting from a reduction in certain future foreign withholding taxes as well as the use of foreign tax credits. As of September 30, 2022 and December 31, 2021, the Company had federal, state, local and foreign taxes payable of $64.9 million and $93.3 million, respectively, which is recorded as a component of accounts payable, accrued expenses and other liabilities on the accompanying condensed consolidated balance sheet.
In the normal course of business, the Company is subject to examination by federal and certain state, local and foreign tax regulators. With a few exceptions, as of September 30, 2022, the Company’s U.S. federal income tax returns for years 2018 through 2021 are open under the normal three-year statute of limitations and therefore subject to examination. State and local tax returns are generally subject to audit from 2016 to 2021. Foreign tax returns are generally subject to audit from 2011 to 2021. Certain of the Company’s affiliates are currently under audit by federal, state and foreign tax authorities.
The Company does not believe that the outcome of these audits will require it to record material reserves for uncertain tax positions or that the outcome will have a material impact on the consolidated financial statements. The Company does not believe that it has any tax positions for which it is reasonably possible that the total amounts of unrecognized tax benefits will significantly increase or decrease within the next twelve months.
On July 1, 2022, the State of New York issued proposed regulations, related to its 2015 law change, that may require corporate managers of investment funds (non broker dealers) to change how they source income to New York state, which may result in an increase in the Company’s taxable income to New York. These regulations will not be effective until promulgated. The Company has not yet determined the effect of these proposed regulations on its tax provision.
On August 16, 2022 the Inflation Reduction Act of 2022 (“IRA”) was signed into law. The IRA enacted a 15% corporate minimum tax effective in 2023, a 1% tax on net share repurchases after December 31, 2022, and created and extended certain tax-related energy incentives. While these tax laws have no immediate effect, the Company is continuing to evaluate the impact of the IRA on its financial statements as further information becomes available.