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Income Taxes
 12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
Below is a summary of the components of the Company’s income before income taxes for the years ended December 31 (in thousands).
 202420232022
U.S.$629,656 $574,458 $560,193 
Non-U.S.757,718 572,671 467,002 
Income before income taxes$1,387,374 $1,147,129 $1,027,195 
 
The components of the expense (benefit) for income taxes on the above income are summarized in the table below (in thousands).
 202420232022
Current tax expense:   
U.S. federal$161,155 $171,917 $122,191 
State and local48,084 51,441 48,482 
Foreign88,318 107,421 91,596 
Total current297,557 330,779 262,269 
Deferred tax (benefit) expense:   
U.S. federal(31,708)(35,457)(21,337)
State and local963 (13,475)(10,108)
Foreign(128,291)(12,845)(4,232)
Total deferred(159,036)(61,777)(35,677)
Total current and deferred138,521 269,002 226,592 
Expense relating to interest rate swaps used to increase equity
(4,695)(4,976)(5,569)
Benefit from stock transactions with employees used to increase equity97 105 66 
Benefit (expense) relating to defined-benefit pension adjustments used to increase equity
(264)532 (1,693)
Total tax expense$133,659 $264,663 $219,396 
 
The components of long-term deferred tax assets (liabilities) are summarized in the table below (in thousands).

 December 31,
 20242023
Accrued liabilities$86,831 $85,328 
Operating leases41,777 59,160 
Intangible assets132,292 92,612 
Property, equipment and leasehold improvements11,592 9,631 
Loss and credit carryforwards61,313 31,454 
Assets relating to equity compensation37,247 29,128 
Other assets16,870 13,126 
Gross deferred tax assets387,922 320,439 
Valuation allowance(76,285)(177,132)
Net deferred tax assets311,637 143,307 
Prepaid expenses(79,559)(69,556)
Other liabilities(18,063)(15,587)
    Gross deferred tax liabilities(97,622)(85,143)
Net deferred tax assets (liabilities)
$214,015 $58,164 
Net deferred tax assets and net deferred tax liabilities were $262.8 million and $48.7 million as of December 31, 2024, respectively, and $144.7 million and $86.6 million as of December 31, 2023, respectively. These amounts are reported in Other assets and Other liabilities in the Consolidated Balance Sheets. Management has concluded it is more likely than not that the reversal of deferred tax liabilities and results of future operations will generate sufficient taxable income to realize the deferred tax assets, net of the valuation allowance at December 31, 2024.

In January 2024, the Company completed an intercompany transfer of certain intellectual property. Prior to the sale, the Company had a $103.1 million deferred tax asset for tax basis in the related IP and a full valuation allowance due to no expected local tax benefit of the asset. As a result of this IP transfer, the deferred tax asset and related valuation allowance were written off with no impact to tax expense.

In December 2024, the Company completed an additional intercompany transfer of certain intellectual property. As a result, the Company recorded a deferred tax asset of approximately $163.2 million. The deferred tax asset represents the value of future tax deductions for amortization of the assets in the acquiring jurisdiction. A portion of the tax amortization was recognized in 2024. The deferred tax asset for intangible assets was reduced for the impact of the 2024 amortization, with the offset reflected as an increase in the deferred tax asset for loss carryforwards. These amounts have been reduced for associated unrecognized tax benefits, consistent with ASC 740, Income Taxes. The fair value of the intellectual property was determined using an income approach based on unobservable inputs and involves significant judgments such as, but not limited to, future cash flows and discount rates. Management’s estimates of fair value are based upon assumptions believed to be reasonable, but which are inherently uncertain and unpredictable and, as a result, actual results may differ from estimates.
 
The valuation allowances of $76.3 million and $177.1 million as of December 31, 2024 and 2023, respectively, primarily related to tax basis in certain intangible assets and loss and credit carryovers that are not likely to be realized.

As of December 31, 2024, the Company had state and local tax net operating loss carryforwards of $8.7 million, of which $4.0 million expires within six to fifteen years and $4.7 million expires within sixteen years to twenty years. The Company also had state tax credits of $6.2 million, a majority of which will expire in five to six years. As of December 31, 2024, the Company had non-U.S. net operating loss carryforwards of $10.5 million, of which $0.2 million expires over the next 20 years and $10.3 million can be carried forward indefinitely. In addition, the Company also had foreign tax credit carryforwards of $24.9 million, all of which will expire between 2029 and 2034. These amounts have been reduced for associated unrecognized tax benefits, consistent with ASC 740, Income Taxes.

The items comprising the differences between the U.S. federal statutory income tax rate and the Company’s effective tax rate on income before income taxes for the years ended December 31 are summarized in the table below.
 202420232022
Statutory tax rate21.0 %21.0 %21.0 %
State income taxes, net of federal benefit2.2 2.1 2.4 
Effect of non-U.S. operations (3.0)(0.4)(2.0)
Intercompany sale of intellectual property(11.8)— — 
Net activity in unrecognized tax benefits
2.0 1.3 (1.1)
Stock-based compensation expense(3.3)(3.1)(2.0)
Limitation on executive compensation2.4 2.3 1.4 
Global intangible low-taxed income, net of foreign tax credits 1.1 1.2 1.9 
Foreign-derived intangible income— (0.3)(0.4)
Change in the valuation allowance(0.1)(1.2)0.3 
Other items, net(0.9)0.2 (0.1)
Effective tax rate9.6 %23.1 %21.4 %

As noted above, in December 2024, the Company completed an additional intercompany transfer of certain intellectual property. As a result, the Company recorded net tax benefits of approximately $161.9 million. The benefit represents the value of future tax deductions for amortization of the assets in the acquiring jurisdiction, net of any tax recognized by the selling jurisdiction. The Company’s intellectual property footprint continues to evolve and may result in tax rate volatility in the future.

The change in valuation allowance in 2024 was largely related to the January transfer of intellectual property noted above. Because both the asset and the related valuation allowance were written off, there is no net income tax expense from the change in valuation allowance. Therefore, no tax expense amount is reflected in the table above.
As of December 31, 2024 and 2023, the Company had gross unrecognized tax benefits of $257.5 million and $148.4 million, respectively. The increase is primarily due to positions taken with respect to certain intercompany transactions. The gross unrecognized tax benefits at December 31, 2024 related primarily to transfer pricing on intercompany transactions, the exclusion of stock-based compensation expense from the Company’s cost sharing agreement, and the ability to realize certain refund claims. It is reasonably possible that gross unrecognized tax benefits will decrease by approximately $11.0 million within the next twelve months due to the anticipated closure of audits and the expiration of certain statutes of limitation.
 
Included in the balance of gross unrecognized tax benefits at December 31, 2024 are potential benefits of $246.5 million that, if recognized, would reduce our effective tax rate on income from continuing operations. Also included in the balance of gross unrecognized tax benefits at December 31, 2024 are potential benefits of $11.1 million that, if recognized, would result in adjustments to other tax accounts, primarily deferred taxes.
 
The table below is a reconciliation of the beginning and ending amounts of gross unrecognized tax benefits, excluding interest and penalties, for the years ended December 31 (in thousands).
 20242023
Beginning balance$148,390 $137,227 
Additions based on tax positions related to the current year116,373 22,822 
Additions for tax positions of prior years7,925 4,361 
Reductions for tax positions of prior years(888)(14)
Reductions for expiration of statutes(10,573)(15,625)
Settlements— (441)
Change in foreign currency exchange rates(3,694)60 
Ending balance$257,533 $148,390 

The Company accrues interest and penalties related to gross unrecognized tax benefits in its income tax provision. As of December 31, 2024 and 2023, the Company had $21.1 million and $17.4 million, respectively, of accrued interest and penalties related to gross unrecognized tax benefits. These amounts are in addition to the gross unrecognized tax benefits disclosed above. The total amount of interest and penalties recognized in the income tax provision during 2024 and 2023 was $5.0 million and $1.8 million, respectively.

The number of years with open statutes of limitation varies depending on the tax jurisdiction. The Company’s statutes are open with respect to the U.S. federal jurisdiction for 2021 and forward, India for 2006 and forward, and Ireland for 2020 and forward. For other major taxing jurisdictions, including U.S. states, the United Kingdom, Canada, Japan, Malta, Cyprus, France, Germany, and Saudi Arabia, the Company’s statutes vary and are open as far back as 2015.

The Organization for Economic Co-operation and Development (“the OECD”) has issued various proposals that would change long-standing global tax principles. These proposals include a two-pillar approach to global taxation, focusing on global profit allocation and a 15% global corporate minimum tax rate.

Several countries in which Gartner does business have proposed or enacted new laws or are actively considering changes to their tax laws to align with OECD proposals. Significant details around the provisions are still uncertain as the OECD and participating countries continue to work on defining the underlying rules and administrative procedures. Enactment of this and similar legislation could significantly increase our tax obligations in countries where we do business. We will continue to monitor and reflect the impact of such legislative changes in future financial statements as appropriate.
Under U.S. GAAP, no provision for income taxes that may result from the remittance of earnings held overseas is required if the Company has the ability and intent to indefinitely reinvest such funds overseas. The Company intends to distribute a portion of the accumulated undistributed earnings of non-U.S. subsidiaries as of December 31, 2024 in conjunction with global restructuring activity. The Company has recorded an income tax expense of approximately $2.6 million during 2024 for the anticipated tax impact of such distribution. The Company continues to assert its intention to reinvest all remaining accumulated undistributed foreign earnings in its non-U.S. operations, except in instances where the repatriation of those earnings would result in minimal additional tax. Consequently, except as noted above, the Company has not recognized income tax expense that would result from the remittance of those earnings. The accumulated undistributed earnings of non-U.S. subsidiaries that have not been previously taxed were approximately $118.1 million as of December 31, 2024.