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Income Taxes
12 Months Ended
Dec. 31, 2023
Income Tax Disclosure [Abstract]  
Income Taxes INCOME TAXES
The following table summarizes the components of Income tax expense:
For the Years Ended December 31,
(in millions of dollars)202420232022
Current tax expense:
Federal$30.7 $33.7 $24.0 
Foreign5.2 3.1 4.1 
State and local6.8 9.1 6.6 
Total current tax expense42.7 45.9 34.7 
Deferred tax expense (benefit):
Federal0.8 — (3.5)
Foreign2.5 (0.5)(0.1)
State and local1.6 0.2 (0.6)
Total deferred tax expense (benefit)4.9 (0.3)(4.2)
Total income tax expense$47.6 $45.6 $30.5 
The following table summarizes the differences between the statutory federal income tax rate and the effective income tax rate:
For the Years Ended December 31,
202420232022
Statutory federal income tax rate21.0 %21.0 %21.0 %
State income taxes, net of federal tax benefit4.0 3.8 4.0 
Valuation allowance(0.2)(0.1)(2.3)
Worthless stock deduction benefits(6.0)— — 
Remeasurement of deferred taxes0.1 (0.1)(0.6)
Foreign-derived intangible income(1.0)(1.7)(0.9)
Executive compensation limitation1.5 1.5 0.7 
Foreign tax rate effects0.6 0.7 0.6 
Excess tax benefits from stock compensation activity(1.9)(1.9)(1.6)
Other, net(0.1)(0.7)(0.7)
Effective income tax rate18.0 %22.5 %20.2 %
The following table summarizes Income before income taxes:
For the Years Ended December 31,
(in millions of dollars)202420232022
U.S.$234.5 $176.6 $132.1 
Non-U.S.29.4 26.4 18.8 
Income before income taxes$263.9 $203.0 $150.9 
Summary
During the year ended December 31, 2023, the Company filed amended U.S. federal income tax returns for the 2015 through 2018 tax years to claim a worthless stock deduction. As of December 31, 2023, the amended tax returns were under examination by the applicable tax authorities and recovery of the refund claim was not considered more-likely-than-not. Accordingly, the aggregate refund claim of $13.6 million, including interest of $1.8 million, was recorded as an income tax receivable as of December 31, 2023, fully offset by a corresponding liability for unrecognized tax benefits.
In the first quarter of 2024, the tax authorities notified the Company that the amended tax returns had been approved, at which point receipt of the refund claim was considered more-likely-than-not. As a result, the Company released the associated liability for unrecognized tax benefits and recognized a $13.0 million discrete tax benefit for the refund claim, net of taxes on the associated interest, for the year ended December 31, 2024. Following the receipt of the U.S. federal income tax refund during the second quarter of 2024, the Company began amending applicable state tax returns to reflect the worthless stock deduction, which resulted in the recognition of additional discrete state tax benefits aggregating to $2.9 million, net of federal tax effects, for the year ended December 31, 2024.
The Company recognized income tax expense of $47.6 million for the year ended December 31, 2024, compared to $45.6 million for the year ended December 31, 2023. The increase in income tax expense in 2024 was primarily due to higher earnings, partially offset by the aforementioned discrete tax benefits, which aggregated to $15.9 million, and the recognition of $5.1 million in excess tax benefits associated with stock-based compensation activity. Including these items, the Company’s effective tax rate for the year ended December 31, 2024 was 18.0%, compared to 22.5% in 2023. The Company’s income tax expense and effective tax rate for the year ended December 31, 2023 also included the effects of the recognition of $3.9 million in excess tax benefits associated with stock-based compensation activity.
The Company recognized income tax expense of $45.6 million for the year ended December 31, 2023, compared to $30.5 million for the year ended December 31, 2022. The increase in income tax expense in 2023 was primarily due to higher earnings and the non-recurrence of certain discrete tax benefits recognized in 2022 associated with the release of valuation allowances, partially offset by a $1.5 million increase in the amount of excess tax benefits from stock compensation activity compared to 2022. In the year ended December 31, 2022, the Company recognized a $2.6 million tax benefit from the release of a valuation allowance that had previously been recorded against deferred tax assets associated with foreign tax credits in the U.S., primarily due to tax planning. The Company also recognized a $1.1 million tax benefit during the year ended December 31, 2022 associated with the release of a valuation allowance in the U.K., as the associated deferred tax assets were
considered more-likely-than-not to be realized primarily due to increased projections of future taxable income. Including these items, the Company’s effective tax rate for the year ended December 31, 2023 was 22.5%, compared to 20.2% in 2022.
The Company paid income taxes of $62.4 million in 2024, $46.2 million in 2023, and $26.9 million in 2022.
Deferred Taxes
The following table summarizes the Company’s deferred tax assets and liabilities:
(in millions of dollars)20242023
Deferred tax assets:
Properties and equipment$3.2 $3.5 
Accrued expenses40.1 34.8 
Stock-based compensation3.5 3.3 
Net operating loss and tax credit carryforwards11.0 14.0 
Goodwill and intangibles4.9 4.8 
Pension benefits14.5 15.6 
Gross deferred tax assets77.2 76.0 
Valuation allowance(0.1)(0.5)
Total deferred tax assets77.1 75.5 
Deferred tax liabilities:
Properties and equipment(48.6)(40.6)
Pension benefits(12.8)(11.9)
Goodwill and intangibles(62.4)(62.4)
Other(1.9)(1.8)
Gross deferred tax liabilities(125.7)(116.7)
Net deferred tax liabilities$(48.6)$(41.2)
The deferred tax asset for net operating loss and tax credit carryforwards at December 31, 2024 includes state net operating loss carryforwards of $2.8 million, which will begin to expire in 2026, and foreign net operating loss carryforwards of $8.2 million, which have an indefinite carryforward period.
The deferred tax asset for tax loss and tax credit carryforwards at December 31, 2023, included state net operating loss carryforwards of $4.5 million and foreign net operating loss carryforwards of $9.5 million.
The $77.1 million of deferred tax assets at December 31, 2024 is anticipated to be realized through future taxable income or the future reversal of existing taxable temporary differences recorded as deferred tax liabilities at December 31, 2024. Should the Company determine that it is not more-likely-than-not to be able to realize its remaining deferred tax assets in the future, an adjustment to the valuation allowance would be recorded in the period such determination is made.
Generally, the Company has considered cash and cash equivalents held by subsidiaries outside the U.S. to be indefinitely reinvested in its foreign operations and the Company’s current plans do not demonstrate a need to repatriate such cash to fund U.S. operations. As of December 31, 2024, the Company continues to assert that its undistributed earnings of certain foreign subsidiaries are indefinitely reinvested. It is not practicable to determine the income tax liability that would be payable if such earnings were not permanently reinvested.
Valuation Allowances
ASC 740, Income Taxes, requires that the future realization of deferred tax assets depends on the existence of sufficient taxable income in future periods. Possible sources of taxable income include taxable income in carryback periods, the future reversal of existing taxable temporary differences recorded as a deferred tax liability, tax-planning strategies that generate future income or gains in excess of anticipated losses in the carryforward period, and projected future taxable income. If, based upon all available evidence, both positive and negative, it is more likely than not such deferred tax assets will not be realized, a valuation allowance is recorded. Significant weight is given to positive and negative evidence that is objectively verifiable. A company’s
three-year cumulative loss position is significant negative evidence in considering whether deferred tax assets are realizable and the accounting guidance restricts the amount of reliance the Company can place on projected taxable income to support the recovery of the deferred tax assets.
We continually evaluate the need to maintain a valuation allowance for deferred tax assets based on our assessment of whether it is more likely than not that deferred tax benefits will be realized through the generation of future taxable income. Appropriate consideration is given to all available evidence, both positive and negative, in assessing the need for a valuation allowance.
As of December 31, 2024, the Company’s valuation allowance was $0.1 million, which represents the estimated amount of state net operating loss carryforwards that are not more-likely-than not to be realized prior to expiration. During the year ended December 31, 2024, the Company’s valuation allowance decreased by $0.4 million, primarily due to increased projections of future taxable income associated with these state net operating loss carryforwards.
Unrecognized Tax Benefits
The following table summarizes the activity related to the Company’s unrecognized tax benefits:
(in millions of dollars)202420232022
Balance at January 1$12.5 $1.2 $1.2 
Increases as a result of tax positions taken in the current year— 11.8 — 
Decreases from prior period positions(11.8)(0.5)— 
Balance at December 31$0.7 $12.5 $1.2 
During the year ended December 31, 2023, the Company filed amended U.S. federal income tax returns for the 2015 through 2018 tax years to claim a worthless stock deduction. As of December 31, 2023, the aggregate refund claim associated with the worthless stock deduction was $13.6 million, including interest of $1.8 million, which was not included in the table above. As recovery of the refund claim was not considered more-likely-than-not as of December 31, 2023, the Company recognized an offsetting increase to its liability for unrecognized tax benefits. In accordance with ASC 740, as of December 31, 2023, the Company had recorded a receivable for the full amount of the refund claim, including interest, and an offsetting liability for unrecognized tax benefits for the same amount. As of December 31, 2023, the receivable and offsetting liability were presented net on the Consolidated Balance Sheet and, as the refund claim was fully reserved, the recognition of the uncertain tax position had no impact on the Consolidated Statements of Operations during the year ended December 31, 2023.
During the year ended December 31, 2024, the tax authorities notified the Company that the amended tax returns had been approved, at which point receipt of the refund claim was considered more-likely-than-not. As a result, the Company released the associated liability for unrecognized tax benefits and recognized a $13.0 million discrete tax benefit for the refund claim, net of taxes on the associated interest, for the year ended December 31, 2024.
The Company’s accounting policy is to recognize interest and penalties related to income tax matters in income tax expense. At both December 31, 2024 and 2023, accruals for interest and penalties amounting to $0.4 million were included in the Consolidated Balance Sheets, but are not included in the table above. Liabilities for unrecognized tax benefits, including interest and penalties, were $1.2 million as of December 31, 2024 and $1.1 million as of December 31, 2023, and were included within Other long-term liabilities on the Consolidated Balance Sheets. These liabilities would impact the Company’s effective tax rate, if recognized. The Company does not expect any significant change to its unrecognized tax benefits as a result of potential expiration of statute of limitations or settlements with the tax authorities within the next twelve months.
Status of Tax Returns
We file U.S., state, and foreign income tax returns in jurisdictions with varying statutes of limitations. The 2021 through 2023 tax years generally remain subject to examination by federal tax authorities, whereas the 2020 through 2023 tax years generally remain subject to examination by most state tax authorities. In significant foreign jurisdictions, the tax years from 2019 through 2022 generally remain subject to examination by their respective tax authorities.