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Income Taxes
12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
Income Taxes
Income before income tax expense (benefit) for the years ended December 31, 2024, 2023 and 2022 was derived from the following sources:

(In thousands)202420232022
Domestic$(239,773)$(457,888)$(272,365)
Foreign561,825 630,558 519,445 
Income before income tax expense (benefit)$322,052 $172,670 $247,080 
Income tax expense (benefit) for the years ended December 31, 2024, 2023 and 2022 is summarized as follows:
(In thousands)202420232022
Current:
Federal$14,786 $10,835 $39,216 
State896 1,267 4,077 
Foreign91,552 125,091 97,611 
$107,234 $137,193 $140,904 
Deferred (net of valuation allowance):
Federal$(73,952)$(135,408)$(90,238)
State(3,225)(5,829)(5,749)
Foreign(1,725)(4,369)(6,757)
$(78,902)$(145,606)$(102,744)
Income tax expense (benefit)$28,332 $(8,413)$38,160 
Income tax expense (benefit) differs from the expected amounts based upon the statutory federal tax rates for the years ended December 31, 2024, 2023 and 2022 as follows:
(In thousands)202420232022
Expected federal income tax at statutory rate$66,657 $36,261 $51,887 
State income taxes before valuation allowance, net of federal tax effect(6,169)(9,374)(5,907)
Effect of foreign source income(25,685)(18,383)(7,607)
Tax contingencies(2,271)11,048 5,762 
Valuation allowance11,501 9,032 8,052 
U.S. federal research credit(14,250)(18,679)(13,525)
Equity compensation5,386 7,431 5,290 
Foreign derived intangible income(7,861)(5,144)(15,265)
Acquisition related retention, severance, and transaction costs— — 8,924 
Legal entity divestiture activity973 (20,311)— 
Other items, net51 (294)549 
Income tax expense (benefit) $28,332 $(8,413)$38,160 
The Company has made employment and spending commitments to Singapore. In return for those commitments, the Company was granted a partial tax holiday for eight years starting in 2013. During 2017, this agreement was extended to 2027 in exchange for revised employment and spending commitments. The income tax benefits attributable to the tax status are $27.7 million ($0.18 per diluted share), $19.7 million ($0.13 per diluted share) and $24.8 million ($0.17 per diluted share) for the years ending December 31, 2024, 2023 and 2022, respectively. The 2024, 2023 and 2022 effective tax rates include additional benefits of $17.1 million, $12.1 million and $14.2 million because the corporate tax rate in Singapore is lower than the U.S. rate.
At December 31, 2024, there were approximately $339.7 million of accumulated undistributed earnings of subsidiaries outside of the United States, all of which are considered to be indefinitely reinvested. Management estimates that approximately $23.0 million of withholding taxes would be incurred if these undistributed earnings were distributed.   
The significant components of the Company’s deferred tax assets and deferred tax liabilities at December 31, 2024 and 2023 are as follows:
(In thousands)20242023
Deferred tax assets attributable to:
Accounts receivable$1,307 $1,304 
Inventory11,891 12,456 
Accruals not currently deductible for tax purposes11,984 16,341 
Net operating loss and credit carryforwards69,461 55,685 
Capital loss carryforward7,542 5,281 
Equity compensation10,701 11,382 
Interest expense limitations51,429 37,691 
Capitalization of engineering, research and development expenses134,398 100,832 
Other, net6,298 15,064 
Gross deferred tax assets$305,011 $256,036 
Valuation allowance(71,785)(60,330)
Net deferred tax assets$233,226 $195,706 
Deferred tax liabilities attributable to:
Purchased intangible assets$(215,906)$(230,550)
Depreciation and amortization(24,853)(44,007)
Total deferred tax liabilities$(240,759)$(274,557)
Net deferred tax liabilities$(7,533)$(78,851)
Deferred tax assets are generally required to be reduced by a valuation allowance if it is more likely than not that some portion or all of the deferred tax assets will not be realized.
As of December 31, 2024 and 2023, the Company had net U.S. deferred tax assets of $20.1 million and deferred tax liabilities of $76.7 million, respectively, which are composed of temporary differences and various tax credit carryforwards. The Company had state operating loss and credit carryforwards of approximately $26.3 million, which begin to expire in 2025. Management believes that it is more likely than not that the benefit from certain state net operating loss carryforwards, state credit carryforwards, capital loss carryforwards and certain federal foreign tax credit carryforwards will not be realized. In recognition of this risk, management has provided valuation allowances of $36.5 million and $29.7 million as of December 31, 2024 and 2023, respectively, on the related deferred tax assets. If the assumptions change and management determines the assets will be realized, the tax benefits relating to any reversal of the valuation allowance on deferred tax assets at December 31, 2024 will be recognized as a reduction of income tax expense.
As of December 31, 2024 and 2023, the Company had net non-U.S. deferred tax assets of $44.2 million and $58.2 million, respectively, for which management determined based upon the available evidence a valuation allowance of $35.3 million and $30.6 million as of December 31, 2024 and 2023, respectively, was required against the non-U.S. gross deferred tax assets. For other non-U.S. jurisdictions, management relies upon projections of future taxable income to utilize deferred tax assets.
At December 31, 2024, the Company had foreign operating loss carryforwards of $64.3 million, which begin to expire in 2025.
Benefits from tax positions should be recognized in the financial statements only when it is more likely than not that the tax positions will be sustained upon examination by the appropriate taxing authority that would have full knowledge of all relevant information. A tax position that meets the more-likely-than-not recognition threshold is measured at the largest amount of benefit that is greater than fifty percent likely of being realized upon ultimate settlement. Tax positions that fail to meet the more-likely-than-not recognition threshold should be recognized in the first subsequent financial reporting period in which that threshold is met. Previously recognized tax positions that no longer meet the more-likely-than-not recognition threshold should be derecognized in the first subsequent financial reporting period in which that threshold is no longer met. The provisions also provide guidance on the accounting for and disclosure of unrecognized tax benefits, interest and penalties.
Reconciliations of the beginning and ending balances of the total amounts of gross unrecognized tax benefits for the years ended December 31, 2024 and 2023 are as follows:
(In thousands)20242023
Gross unrecognized tax benefits at beginning of year$67,717 $53,478 
Increase in tax positions from prior years305 242 
Decrease in tax positions from prior years(4,818)— 
Increases in tax positions for current year5,455 17,111 
Settlement of tax positions for current year(21,570)— 
Lapse in statute of limitations(2,765)(3,114)
Gross unrecognized tax benefits at end of year$44,324 $67,717 
The total amount of net unrecognized tax benefits that, if recognized, would affect the effective tax rate was $39.3 million at December 31, 2024.
Penalties and interest paid or received are recorded in other expense, net in the consolidated statements of operations. As of December 31, 2024 and 2023, the Company had accrued interest and penalties related to unrecognized tax benefits of $6.0 million and $6.6 million, respectively. Expenses of $3.0 million, $2.5 million and $2.0 million were recognized as interest and penalties in the consolidated statements of operations for the years ended December 31, 2024, 2023 and 2022, respectively.
The Company files income tax returns in the U.S. and in various state, local and foreign jurisdictions. The statutes of limitations related to both the consolidated federal income tax return and state returns are closed for all years up to and including 2020 and 2020, respectively. With respect to foreign jurisdictions, the statute of limitations varies from country to country, with the earliest open year for the Company’s major foreign subsidiaries being 2018.
Due to the expiration of various statutes of limitations and settlements of audits, it is reasonably possible that the Company’s gross unrecognized tax benefit balance may decrease within the next twelve months by approximately $0.2 million.
The Organization Economic Co-operation and Development (“OECD”) introduced Base Erosion and Profit Shifting (“BEPS”) Pillar 2 rules that impose a global minimum tax rate of 15%. Numerous countries, including European Union member states, have enacted or are expected to enact legislation to be effective as early as January 1, 2024, with general implementation of a global minimum tax by January 1, 2025. There was no material impact in 2024 and we continue to evaluate the future potential impact on our consolidated financial statements and related disclosures.