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INCOME TAXES
 9 Months Ended
Sep. 30, 2025
Income Tax Disclosure [Abstract]  
INCOME TAXES INCOME TAXES
A reconciliation of the provision for income taxes using the statutory federal income tax rate to our effective income tax rate is as follows below.
Three Months Ended September 30,Nine Months Ended September 30,
2025202420252024
Federal statutory rate21.0 %21.0 %21.0 %21.0 %
State income taxes, net of federal benefit2.4 3.2 2.3 2.7 
Share based payment awards(3.8)(2.7)(3.3)(1.4)
Foreign tax credits(2.0)13.7 (2.0)3.8 
Other U.S. tax credits and incentives0.3 (5.1)(0.9)(5.8)
Foreign tax rate differential0.5 (4.5)(0.4)(0.4)
Business divestitures(1)
— 7.9 — 2.8 
Section 162(m) limitation on compensation1.6 1.1 1.5 1.0 
Other0.6 (2.2)0.7 (0.7)
Effective income tax rate20.6 %32.4 %18.9 %23.0 %
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(1) Amounts in the three and nine months ended September 30, 2024 relate to the divestiture of our Europe Surface Transportation business. Refer to Note 14, Divestitures, for further discussion.
In 2021, the Organization for Economic Cooperation and Development 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 continuing to evaluate the impact of enacted legislation and pending legislation to enact Pillar Two Model Rules in the tax jurisdictions we operate in.
On July 4, 2025, the One Big Beautiful Bill Act (the “OBBBA” or the “Act”) was signed into law. The OBBBA makes permanent key elements of the Tax Cuts and Jobs Act, including 100 percent bonus depreciation, domestic research cost expensing, and the business interest expense limitation. The Act also included modifications to the international tax framework. ASC 740, “Income Taxes,” requires the effects of changes in tax rates and laws on deferred tax balances to be recognized in the period in which the legislation is enacted. We will evaluate all deferred tax balances under the newly enacted tax law and identify any changes required to our financial statements as a result of the OBBBA. The legislation has multiple effective dates, with certain provisions effective in 2025 and others effective through 2027. As of September 30, 2025, we have not recorded any adjustments related to the OBBBA. We are continuing to assess its impact on our consolidated financial statements and will update our disclosures as necessary in future periods.
As of September 30, 2025, we have $42.8 million of unrecognized tax benefits and related interest and penalties. It is possible the amount of unrecognized tax benefits could change in the next 12 months as a result of a lapse of the statute of limitations, new information, or settlements with taxing authorities. The total liability for unrecognized tax benefits is expected to decrease by approximately $1.2 million in the next 12 months due to the lapsing of statutes of limitations. 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.