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INCOME TAXES
 12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
INCOME TAXES INCOME TAXES
C.H. Robinson Worldwide, Inc., and its 80 percent (or more) owned U.S. subsidiaries file a consolidated federal income tax return. We file unitary or separate state returns based on state filing requirements. With few exceptions, we are no longer subject to audits of U.S. federal, state and local, or non-U.S. income tax returns before 2020.
The company is no longer indefinitely reinvested with regard to the unremitted earnings of any foreign subsidiaries. The company remains indefinitely reinvested related to other taxable differences that may exist with regard to these subsidiaries.
In 2021, the Organization for Economic Cooperation and Development (“OECD”) announced an Inclusive Framework on Base Erosion and Profit Shifting including Pillar Two Model Rules defining the global minimum tax, which calls for the taxation of large multinational corporations at a minimum rate of 15 percent. Subsequently, multiple sets of administrative guidance have been issued. Many non-U.S. tax jurisdictions have either recently enacted legislation to adopt certain components of the Pillar Two Model Rules beginning in 2024 (including the European Union Member States) with the adoption of additional components in later years or announced their plans to enact legislation in future years. We are subject to these rules in certain jurisdictions in which we operate, and any expected tax impacts have been included in our results. As rules for more jurisdictions will become effective in 2025, we will continue to evaluate the impact of enacted and pending legislation to Pillar Two Model Rules in the tax jurisdictions we operate in.
Income before provision for income taxes consisted of (in thousands):
Twelve Months Ended December 31,
202420232022
Domestic$336,328 $287,524 $799,553 
Foreign242,876 121,662 367,212 
Total$579,204 $409,186 $1,166,765 
A reconciliation of the beginning and ending amount of unrecognized tax benefits, excluding interest and penalties, is as follows (in thousands):
As of December 31,
202420232022
Unrecognized tax benefits, beginning of period$16,916 $39,056 $37,302 
Additions based on tax positions related to the current year2,747 2,111 4,064 
Additions for tax positions of prior years2,168 1,268 3,016 
Reductions for tax positions of prior years(582)(91)(247)
Lapse in statute of limitations(1,182)(2,346)(5,026)
Settlements(317)(23,082)(53)
Unrecognized tax benefits, end of the period$19,750 $16,916 $39,056 
Income tax expense considers amounts that may be needed to cover exposures for open tax years. We do not expect any material impact related to open tax years; however, actual settlements may differ from amounts accrued.
As of December 31, 2024, we had $23.5 million of unrecognized tax benefits and related interest and penalties, all of which would affect our effective tax rate if recognized. In the unlikely event these unrecognized tax benefits and related interest and penalties were recognized fully in 2024, the impact to the annual effective tax rate would have been 4.1 percent. We are not aware of any tax positions for which it is reasonably possible that the total amount of unrecognized tax benefit will significantly increase or decrease in the next 12 months. The total liability for unrecognized tax benefits is expected to decrease by approximately $1.1 million in the next 12 months due to lapsing of statutes.
We recognize interest and penalties related to uncertain tax positions in the provision for income taxes. During the years ended December 31, 2024, 2023, and 2022, we recognized approximately $0.7 million, $0.7 million, and $0.6 million in interest and penalties, respectively. We had approximately $3.7 million and $3.2 million for the payment of interest and penalties related to uncertain tax positions accrued within noncurrent income taxes payable as of December 31, 2024 and 2023, respectively. These amounts are not included in the reconciliation above.
The components of the provision for income taxes consist of the following (in thousands): 
Twelve Months Ended December 31,
202420232022
Tax provision:
Federal$135,807 $55,149 $153,349 
State23,081 4,014 33,309 
Foreign32,885 62,426 97,147 
191,773 121,589 283,805 
Deferred provision (benefit):
Federal(83,702)(32,820)(44,133)
State(10,379)6,223 (7,848)
Foreign15,822 (10,935)(5,583)
(78,259)(37,532)(57,564)
Total provision$113,514 $84,057 $226,241 
A reconciliation of the provision for income taxes using the statutory federal income tax rate to our effective income tax rate is as follows:  
Twelve Months Ended December 31,
2024
2023(1)
2022(1)
Federal statutory rate21.0 %21.0 %21.0 %
State income taxes, net of federal benefit1.9 2.1 2.1 
Section 199 deduction— 4.7 — 
Share-based payment awards(1.8)(2.7)(1.2)
Foreign tax credits2.5 (9.5)(1.2)
Other U.S. tax credits and incentives(5.3)(3.4)(2.0)
Foreign tax rate differential(0.4)5.8 0.6 
Remeasurement of deferred tax balances(1.1)— — 
Business divestitures(2)
1.3 0.9 — 
Section 162(m) limitations on compensation1.3 1.2 0.6 
Other0.2 0.4 (0.5)
Effective income tax rate19.6 %20.5 %19.4 %
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(1) The amounts as of December 31, 2023 and 2022 have been adjusted to conform to current year presentation.
(2) Amounts in 2024 relate to the divestiture of our Europe Surface Transportation business. Amounts in 2023 relate to the divestiture of our Argentina operations. Refer to Note 15, Divestitures, for further discussion related to these divestitures.
Deferred tax assets (liabilities) are comprised of the following (in thousands):
As of December 31,
20242023
Deferred tax assets:
Lease liabilities$72,532 $74,495 
Compensation64,202 64,788 
Accrued expenses42,718 33,720 
Tax credit carryforward— 14,485 
Foreign affiliate prepayment49,409 — 
Foreign net operating loss carryforwards
69,555 67,816 
Long-lived assets109,308 104,005 
Other
32,855 22,220 
   Total deferred tax assets (before valuation allowance)
440,579 381,529 
   Less: valuation allowance
(64,198)(62,183)
   Total deferred tax assets376,381 319,346 
Deferred tax liabilities:
Right-of-use assets(64,686)(68,764)
Intangible assets(868)(25,773)
Prepaid assets(4,928)(4,405)
Foreign withholding tax(10,645)(10,313)
Other(6,910)(8,649)
   Total deferred tax liabilities(88,037)(117,904)
Net deferred tax assets$288,344 $201,442 
We had foreign net operating loss carryforwards with a tax effect of $69.6 million as of December 31, 2024, and $67.8 million as of December 31, 2023. The net operating loss carryforwards will expire at various dates from 2025 to 2030, with certain jurisdictions having indefinite carryforward terms. We continually monitor and review the foreign net operating loss carryforwards to determine the ability to realize the deferred tax assets associated with the foreign net operating loss carryforwards. As of December 31, 2024 and 2023, we have recorded a valuation allowance of $64.2 million and $62.2 million, respectively, against the deferred tax asset related to the foreign operating loss carryforwards that are primarily in Luxembourg.