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Income Taxes | 9 Months Ended
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Sep. 30, 2025
Income Tax Disclosure [Abstract] |
Income Taxes | 13. Income Taxes The Company recorded a provision for income taxes of $20.9 million and $10.4 million for the three months ended September 30, 2025 and 2024, respectively, and a provision for income taxes of $38.1 million and $20.1 million for the nine months ended September 30, 2025 and 2024, respectively. The provisions for income taxes for the three and nine months ended September 30, 2025 and 2024 were primarily driven by the statutory tax expense for domestic and foreign jurisdictions for the respective fiscal years, offset by tax benefits from excess stock-based compensation deductions. The provision for income taxes for the three and nine months ended September 30, 2025 includes the impact from the tax legislation, referred to as the One Big Beautiful Bill Act (“OBBBA”), which was enacted in the third quarter of 2025 and is further discussed below. During both the three months ended September 30, 2025 and 2024, the Company paid foreign withholding taxes of $5.1 million. During the nine months ended September 30, 2025 and 2024, the Company paid foreign withholding taxes of $16.1 million and $15.5 million, respectively. As of December 31, 2024, the Company had $203.8 million of unrecognized tax benefits, before interest accrual, including $22.8 million recorded as a reduction of long-term deferred tax assets, $74.8 million recorded as a reduction of other assets associated with refundable withholding taxes previously withheld from licensees in South Korea, and $106.2 million recorded to long-term income taxes payable, primarily comprised of $105.1 million in income taxes payable related to withholding taxes previously withheld from licensees in South Korea. As of September 30, 2025, the Company had approximately $107.6 million of unrecognized tax benefits, before interest accrual, including $23.9 million recorded as a reduction of long-term deferred tax assets, $82.7 million recorded as a reduction of other assets associated with refundable withholding taxes previously withheld from licensees in South Korea, and $1.0 million recorded to long-term income taxes payable. On September 18, 2025, the South Korean Supreme Court ruled that the use of any patents in South Korea constitutes domestic source income under the South Korea–U.S. Tax Treaty, even if such patents are not registered with the patent office in South Korea. Based on this ruling, patent license royalties are subject to South Korean withholding tax if the patents are used in South Korea. As a result of this ruling, Rambus determined that it is not more likely than not that withholding taxes paid in South Korea are recoverable. The Company previously filed refund claims for withholding taxes paid in South Korea in the amount of $82.7 million related to the period from the fourth quarter of 2018 through the third quarter of 2023. The Company previously intended to file additional refund claims in the future for $32.2 million of withholding taxes paid from the fourth quarter of 2023 through the second quarter of 2025. The Company had previously recorded long-term tax receivables of $114.9 million and $105.1 million, before interest accrual, related to these refund claims as of June 30, 2025, and December 31, 2024, respectively. If the South Korea withholding taxes are recovered through the refund claim process, the U.S. foreign tax credit claimed for these withholding taxes on historical federal tax returns will be forfeited. Therefore, the Company had also recorded a long-term tax payable of $114.9 million and $105.1 million as of June 30, 2025, and December 31, 2024, respectively. These amounts excluded interest and reflected the future U.S. federal tax liability in the event of filing amended federal tax returns to revise the foreign tax credit amounts. The recovery of South Korea withholding taxes paid before the fourth quarter of 2018 of $74.8 million was uncertain due to the statute of limitations for filing a refund claim. Thus, the Company did not previously record a long-term tax receivable and included this amount in the uncertain tax benefit. As a result of the September 2025 ruling, the Company recorded an uncertain tax position reserve on the $82.7 million of outstanding refund claims, reducing the previously recorded long-term tax receivable for these refund claims to zero, as it determined it is not more likely than not that the withholding taxes paid in South Korea are recoverable. The Company also removed the $32.2 million long-term tax receivable previously recorded for withholding taxes paid during the fourth quarter of 2023 through the second quarter of 2025. As a result, the total long-term tax receivable balance of $114.9 million, excluding interest, was reduced to zero in the current period. The related long-term tax payable of $114.9 million, excluding interest, was also reduced to zero, resulting in zero tax expense impact. Additionally, the Company’s future effective tax rates could be adversely affected by earnings being higher than anticipated in countries where the Company has higher statutory rates or lower than anticipated in countries where it has lower statutory rates, by changes in valuation of its deferred tax assets and liabilities or by changes in tax laws or interpretations of those laws. On July 4, 2025, the United States enacted federal tax legislation commonly referred to as the OBBBA. Included in this legislation are provisions that allow for the immediate expensing of domestic United States research and development expenses, immediate expensing of certain capital expenditures, and other changes to the U.S. taxation of profits derived from foreign operat ions. As a result of the enactment of the legislation, there was an increase to tax expense, primarily related to changes in the taxation of profits derived from foreign operations, and more specifically, the foreign-derived intangible income deduction.

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