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Income Taxes
 9 Months Ended
Sep. 30, 2025
Income Tax Disclosure [Abstract]  
Income Taxes 10. Income Taxes
 
Three Months Ended
September 30,
Nine Months Ended
September 30,
 
2025
2024
2025
2024
 
(Dollars in millions)
Provision (benefit) for income taxes
$(26.7)
$173.1
$98.2
$264.5
Effective tax rate
(31)%
22%
14%
23%
The effective tax rate for the three months ended September 30, 2025 and 2024 primarily comprised the 21% U.S. federal
corporate income tax rate, the impact of U.S. state and foreign income taxes and disallowed executive compensation, offset by
non-controlling interest and equity-based compensation deductions. The effective tax rate for the three months ended
September 30, 2025 was negative primarily due to the tax benefit from the pretax loss incurred prior to the effect of non-
controlling interest and due to the deduction related to the excess tax benefit from the vesting of restricted stock units in the
quarter. The effective tax rate for the nine months ended September 30, 2025 and 2024 primarily comprised the 21% U.S.
federal corporate income tax rate, the impact of U.S. state and foreign income taxes, and disallowed executive compensation,
primarily offset by equity-based compensation deductions and non-controlling interest. The effective tax rate for the nine
months ended September 30, 2024 also includes an increase related to other non-deductible expenses.
As of September 30, 2025 and December 31, 2024, the Company had federal, state, local and foreign taxes payable of
$90.6 million and $46.2 million, respectively, which is recorded as a component of accounts payable, accrued expenses and
other liabilities on the accompanying condensed consolidated balance sheets.
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, 2025, the Company’s U.S. federal income tax returns for the years 2021
through 2024 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 2019 to 2024. Foreign tax returns are generally subject to audit from 2011 to
2024. 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 the audits will require it to record material reserves for uncertain tax
positions or that the outcome will have a material impact on the condensed 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 August 16, 2022, the Inflation Reduction Act of 2022 (the “IRA”) was signed into law. The IRA enacted a 15%
CAMT on the “adjusted financial statement income” of certain large corporations, which became effective on January 1, 2023.
The Company does not expect the IRA to have a material impact to its provision for income taxes given that any current year
payments that would be made under CAMT would be permitted to be carried forward and used as credits in future years
resulting in a deferred tax benefit. The Company will continue to monitor as additional guidance is released by U.S. Department
of the Treasury, the Internal Revenue Service, and other standard-setting bodies.
In October 2021, the OECD introduced a 15% global minimum tax under the Pillar Two GloBE model rules. There are a
number of key provisions under the rules that became effective in 2024 and others that will be phased in during 2025. Several
OECD member countries have enacted the tax legislation based on certain elements of these rules that became effective on
January 1, 2024, and additional countries have drafted or announced an intent to implement legislation. While Pillar Two has
not had a material impact to the Company’s provision for income taxes, the rules remain subject to significant negotiation and
potential change, and the timing and ultimate impact of any such changes on our tax obligations are uncertain. The Company
will continue to monitor as additional countries enact legislation, new parts of the regime come into force or additional
guidance is released by the OECD and other standard-setting bodies.
On July 4, 2025, the One Big Beautiful Bill Act (the “OBBBA”) was signed into law. The OBBBA extends several
provisions from the 2017 Tax Cuts and Jobs Act along with other domestic and international corporate tax provisions. The
OBBBA did not have a material impact on the Company’s provision for income taxes for the three and nine months ended
September 30, 2025, but the Company will continue to monitor as additional guidance is released by U.S. Department of the
Treasury, the Internal Revenue Service, and other standard-setting bodies.