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Income Taxes
 6 Months Ended
Jun. 30, 2024
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The gross liability for unrecognized tax benefits at June 30, 2024 and December 31, 2023 was $17,233 and $15,532, respectively, exclusive of interest and penalties, of which $16,869 and $14,878 would affect the effective tax rate if the Company were to recognize the tax benefit.
The Company classifies interest and penalties on unrecognized tax benefits as income tax expense. As of June 30, 2024 and December 31, 2023, the combined amount of accrued interest and penalties related to tax positions taken on tax returns was $1,989 and $1,385, respectively.
June 30, 2024December 31, 2023
Gross liability for unrecognized tax benefits, exclusive of interest and penalties$17,233 $15,532 
Interest and penalties on unrecognized benefits1,989 1,385 
Total gross uncertain tax positions$19,222 $16,917 
Amount included in Current liabilities$3,685 $3,837 
Amount included in Other long-term liabilities15,537 13,080 
$19,222 $16,917 
The effective income tax rate for the three and six months ended June 30, 2024 and 2023 differs from the federal income tax statutory rate due to the following:
Three Months Ended June 30,Six Months Ended June 30,
2024202320242023
Statutory rate21.0 %21.0 %21.0 %21.0 %
State taxes, net of federal tax benefit2.9 2.8 2.9 2.8 
Foreign tax expense and tax rate differential0.1 (0.2)0.1 (0.2)
Tax benefit from stock option exercises(0.1)(0.1)(0.6)(0.2)
Other, net— (0.1)— 0.1 
23.9 %23.4 %23.4 %23.5 %
The Company files income tax returns in the United States on a consolidated basis and in many U.S. state and foreign jurisdictions. The Company is subject to examination of income tax returns by the Internal Revenue Service (IRS) and other domestic and foreign tax authorities. The Company is no longer subject to U.S. federal income tax examination for years before 2020 and is no longer subject to state, local or foreign income tax examinations by authorities for years before 2018.
The Company estimates it will recognize $3,685 of gross unrecognized tax benefits. This amount is expected to be paid within one year or to be removed at the expiration of the statute of limitations and resolution of income tax audits and is netted against the current payable account. These unrecognized tax benefits are related to tax positions taken on certain federal, state, and foreign tax returns. However, the timing of the resolution of income tax examinations is highly uncertain, and the amounts ultimately paid, if any, upon resolution of the issues raised by the taxing authorities may differ materially from the amounts accrued for each year. While it is reasonably possible that some issues under examination could be resolved in the next twelve months, based upon the current facts and circumstances, the Company cannot reasonably estimate the timing of such resolution or the total range of potential changes as it relates to the current unrecognized tax benefits that are recorded as part of the Company’s financial statements.
The Organization for Economic Co-operation and Development (OECD) has a framework to implement a global minimum corporate tax of 15% for companies with global revenues and profits above certain thresholds (referred to as Pillar Two). Certain aspects of Pillar Two are effective January 1, 2024 and other aspects are effective January 1, 2025. While it is uncertain whether the U.S. will enact legislation to adopt Pillar Two, certain countries in which we operate have adopted legislation, and other countries are in the process of introducing legislation to implement Pillar Two. We do not expect Pillar Two to have a material impact on our effective tax rate or our consolidated results of operation, financial position, or cash flows.