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Income Taxes
3 Months Ended
Jun. 30, 2024
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
In connection with the Transaction Agreements (as defined and described in note 13), the Company recorded a $11.3 million decrease to deferred tax assets during the three months ended June 30, 2024 as a result of the 2024 Exchange (as defined below). In addition, there were exchanges of Class B units and Class C units of the Partnership for Class A common stock by certain limited partners of the Partnership during the three months ended June 30, 2024, resulting in a $25.6 million increase in deferred tax assets and a $2.5 million increase in the valuation allowance. Additionally, a corresponding Tax Receivable Agreements liability of $18.3 million was recorded, representing 85% of the incremental net cash tax savings for the Company as a result of these exchanges. The Company made payments of $9.8 million and $7.7 million during the three months ended June 30, 2024 and 2023, respectively, under the Tax Receivable Agreements. As of June 30, 2024, the Company’s total Tax Receivable Agreements liability was $215.3 million. See note 12 for more information on the Tax Receivable Agreements.
The Company’s effective tax rate was 12.4% and 14.8% for the three months ended June 30, 2024 and 2023, respectively. The Company’s overall effective tax rate in each of the periods described above is less than the statutory rate as a portion of income was allocated to non-controlling interests and the tax liability on such income is borne by the holders of non-controlling interests. For the three months ended June 30, 2024 as compared to the three months ended June 30, 2023, the primary rate difference was due to a decrease in tax expense associated with income allocated to non-controlling interests, partially offset by certain tax expense adjustments that were recorded to the Company’s outside tax basis difference in the Partnership for the three months ended June 30, 2023 that did not reoccur during the three months ended June 30, 2024.
The Company continues to monitor and evaluate legislative developments related to the proposed Global Anti-Base Erosion (“GloBE”) Model Rules established under the Organization for Economic Co-operation and Development’s Pillar Two framework. Several countries where the Company operates have adopted GloBE into their legislation, and additional countries are anticipated to adopt these rules in the future. To date, these legislative changes have not had a material impact on the Company’s effective tax rate.
The Company evaluates the realizability of its deferred tax assets on a quarterly basis and adjusts the valuation allowance when it is more-likely-than-not that all or a portion of the deferred tax assets may not be realized.
As of June 30, 2024, the Company has not recorded any unrecognized tax benefits and does not expect there to be any material changes to uncertain tax positions within the next 12 months.