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Income Taxes
12 Months Ended
Dec. 31, 2023
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
For the years ended December 31, 2023, 2022, and 2021, the Company’s income from continuing operations before provision for income taxes was as follows:

 Year Ended
December 31,
 202320222021
Domestic$385.8 $37.8 $185.3 
Foreign168.6 154.9 114.0 
Income before income taxes$554.4 $192.7 $299.3 
The components of the (provision for) benefit from income taxes in the years ended December 31, 2023, 2022, and 2021, were as follows:

 Year Ended
December 31,
 202320222021
Current:
Federal$(37.6)$(13.2)$(0.4)
State(14.6)(15.3)(0.7)
Foreign(10.7)(7.5)(2.5)
Deferred:
Federal(23.0)386.7 2.2 
State2.7 30.0 0.4 
Foreign(17.6)(20.2)37.5 
(Provision for) benefit from income taxes$(100.8)$360.5 $36.5 

    
A reconciliation of income taxes at the statutory federal income tax rate to the benefit from (provision for) income taxes included in the accompanying consolidated statements of operations is as follows:

 Year Ended
December 31,
 202320222021
Provision for income taxes at federal statutory rate$(116.4)$(40.5)$(62.8)
State taxes, net of federal benefit(14.6)(4.9)(5.5)
Foreign rate differential(20.9)(34.0)0.9 
Research and other credits60.9 45.3 38.1 
Non-deductible compensation(7.4)(3.4)(6.2)
Permanent differences(0.8)(1.8)(0.8)
Change in valuation allowance(2.4)409.9 51.4 
Stock-based compensation2.7(4.3)23.5 
Other non-deductible items(1.9)(5.8)(2.1)
(Provision for) benefit from income taxes$(100.8)$360.5 $36.5 

The significant components of the Company’s deferred tax assets and liabilities as of December 31, 2023 and 2022 were as follows:

 As of December 31,
 20232022
Deferred tax assets:
Net operating loss carryforwards$18.9 $40.8 
Research credit carryforwards217.1 268.9 
Stock-based compensation24.8 24.1 
Accruals and reserves29.0 36.8 
Lease liability72.5 141.8 
Convertible senior notes37.1 47.5 
Capitalized research expenditures233.3 123.9 
Other0.2 0.6 
Gross deferred tax assets632.9 684.4 
Valuation allowance(116.3)(111.6)
Total deferred tax assets, net of valuation allowance516.6 572.8 
Deferred tax liabilities:
Fixed assets and intangible assets21.8 14.4 
Right-of-use assets31.4 59.5 
Other3.0 0.2 
Total deferred tax liability56.2 74.1 
Net deferred tax assets$460.4 $498.7 

The Company periodically evaluates the realizability of its net deferred tax assets based on all available evidence, both positive and negative. The realization of net deferred tax assets is dependent on the Company's ability to generate sufficient future taxable income during periods prior to the expiration of tax attributes to fully utilize these assets. As of December 31, 2023, the Company continues to maintain valuation allowances against its deferred tax assets in certain states and one foreign jurisdiction.
As of December 31, 2023, the Company had $10.7 million of federal, $41.1 million of state, and $25.0 million of foreign net operating loss carryforwards available to reduce future taxable income. Of the federal net operating loss carryforwards, $5.7 million will begin to expire in 2032 and $5.0 million will carryforward indefinitely, while state net operating losses begin to expire in 2038. The foreign net operating loss carryforwards will carryforward indefinitely.
As of December 31, 2023, the Company had research credit carryforwards of $203.0 million and $171.0 million for federal and state income tax purposes, respectively, of which $89.3 million and $44.8 million is the unrecognized tax benefit portion related to the research credit carryforwards for federal and state, respectively. The federal and state credit carryforwards will begin to expire in 2039 and 2032, respectively.
As of December 31, 2023, the Company had $0.5 million of foreign tax credit carryforwards, which will carryforward indefinitely. The Company also had $3.1 million of state enterprise zone credit carryforwards, which will begin to expire in 2024.
Under Section 382 and 383 of the Internal Revenue Code of 1986, as amended, or the Code, if a corporation undergoes an “ownership change,” the corporation’s ability to use its pre-change net operating loss carryforwards and other pre-change attributes, such as research tax credits, to offset its post-change income may be limited. In general, an “ownership change” will occur if there is a cumulative change in our ownership by “5-percent shareholders” that exceeds 50 percentage points over a rolling three-year period. Similar rules may apply under state tax laws. The Company has determined that it has experienced multiple ownership changes and, as a result, the annual utilization of its net operating loss carryforwards and other pre-change attributes will be subject to limitation. However, the Company does not expect that the annual limitations will significantly impact its ability to utilize its net operating loss or tax credit carryforwards prior to expiration.
As of December 31, 2023, the balance of unrecognized tax benefits was $149.8 million of which $106.0 million, if recognized, would affect the effective tax rate and $43.8 million would result in adjustment to deferred tax assets with corresponding adjustments to the valuation allowance.
A reconciliation of the beginning and ending amount of unrecognized tax benefit is as follows:

 Year Ended
December 31,
 202320222021
Balance of gross unrecognized tax benefits at the beginning of the fiscal year$127.2 $107.3 $91.4 
Gross increases related to prior period tax positions3.4 — — 
Gross decreases related to prior period tax positions(0.7)— (0.3)
Gross increases related to current period tax positions21.1 20.3 18.5 
Reductions due to lapse in statute of limitations(1.2)(0.4)(1.5)
Reductions due to settlements with taxing authorities— — (0.8)
Balance of gross unrecognized tax benefits at the end of the fiscal year$149.8 $127.2 $107.3 
The Company recognizes interest and/or penalties related to income tax matters as a component of income tax expense. As of December 31, 2023, the amount of accrued interest and penalties related to uncertain tax positions was $6.7 million. Interest and penalties recognized for the years ended December 31, 2023, 2022, and 2021 was $1.3 million, $1.7 million, and $0.4 million, respectively.
It is reasonably possible that there could be changes to the amount of uncertain tax positions due to activities of the taxing authorities, settlement of audit issues, reassessment of existing uncertain tax positions, or the expiration of applicable statutes of limitations; however, the Company is not able to estimate the impact of these items at this time.
The Company files income tax returns in the U.S. federal, multiple states, and foreign jurisdictions. All of the Company’s tax years from 2009 remain open for examination by the federal and state authorities, and from 2015 by foreign authorities.
The Company generally does not provide deferred income taxes for the undistributed earnings of its foreign subsidiaries that the Company intends to reinvest indefinitely. Should circumstances change and it becomes apparent that some or all of the undistributed earnings will no longer be indefinitely reinvested, the Company will accrue for income taxes not previously recognized. As of December 31, 2023, there was no deferred tax liability on undistributed earnings, and the Company determined the amount of undistributed deferred tax liability to be immaterial.
The Organization for Economic Cooperation and Development (“OECD”) and many countries have proposed to reallocate some portion of profits of large multinational companies with global revenues exceeding EUR20 billion to markets where sales arise (“Pillar One”), as well as enact a global minimum tax rate of at least 15% for multinationals with global revenue exceeding EUR750 million (“Pillar Two”), and many countries are considering or intend to adopt these proposals. In December 2022, the Council of the European Union (“EU”) formally adopted the EU Minimum Tax Directive, which would require member states to adopt Pillar Two into their domestic law. The directive requires the rules to initially become effective for fiscal years starting on or after December 31, 2023. Ireland and certain jurisdictions in which we operate have enacted legislation to implement Pillar Two. Other countries are actively considering changes to their tax laws to adopt certain parts of the OECD’s proposals. The enactment of Pillar Two legislation is not expected to have a material adverse effect on the Company's effective tax rate, financial position, results of operations, and cash flows. The Company will continue to monitor and reflect the impact of such legislative changes in future financial statements as appropriate.