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Income Taxes
 12 Months Ended
Dec. 31, 2023
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The Company’s consolidated income tax provision includes taxes attributable to the controlling interest and, to a lesser extent, taxes attributable to the non-controlling interests.
The following table presents the consolidated provision for income taxes:
 For the Years Ended December 31,
 202120222023
Controlling interest:   
Current taxes$144.4 $315.4 $146.9 
Intangible-related deferred taxes52.5 32.0 29.8 
Other deferred taxes32.7 0.0 1.6 
Total controlling interest229.6 347.4 178.3 
Non-controlling interests:   
Current taxes$15.4 $10.9 $7.0 
Deferred taxes6.0 — — 
Total non-controlling interests21.4 10.9 7.0 
Income tax expense$251.0 $358.3 $185.3 
Income before income taxes (controlling interest)$795.3 $1,493.3 $851.2 
Effective tax rate (controlling interest)(1)
28.9 %23.3 %20.9 %
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(1)Taxes attributable to the controlling interest divided by income before income taxes (controlling interest).
The consolidated provision for income taxes consisted of the following:
 For the Years Ended December 31,
 202120222023
Current:   
Federal$73.1 $222.9 $105.2 
State19.6 30.6 10.8 
Foreign67.1 72.8 37.9 
Total current159.8 326.3 153.9 
Deferred:   
Federal$55.9 $30.4 $27.3 
State13.0 9.0 7.0 
Foreign22.3 (7.4)(2.9)
Total deferred91.2 32.0 31.4 
Income tax expense$251.0 $358.3 $185.3 
For financial reporting purposes, Income before income taxes consisted of the following:
 For the Years Ended December 31,
 202120222023
Domestic$698.2 $639.0 $782.3 
International442.8 1,107.4 309.1 
Total$1,141.0 $1,746.4 $1,091.4 
The following table reconciles the U.S. federal statutory tax rate to the Company’s effective tax rate:
 For the Years Ended December 31,
 202120222023
Statutory U.S. federal tax rate21.0 %21.0 %21.0 %
State income taxes, net of federal benefit3.5 3.5 3.5 
Foreign operations(1.7)(1.7)(4.1)
Compensation plans2.0 0.8 1.1 
Changes in tax laws2.4 — — 
Change in valuation allowances1.1 0.3 (0.1)
Unrecognized tax benefits0.1 0.4 0.6 
BPEA Transaction(1)
— (1.0)— 
Changes in U.S. tax provision to return0.4 0.0 (0.7)
Other0.1 0.0 (0.4)
Effective tax rate (controlling interest)28.9 %23.3 %20.9 %
Effect of income from non-controlling interests(6.9)(2.8)(3.9)
Effective tax rate22.0 %20.5 %17.0 %
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(1)The year ended December 31, 2022 is reflective of the BPEA Transaction gain of $641.9 million and realized and unrealized gains on EQT ordinary shares of $43.8 million and $57.9 million, respectively.
The Company’s effective tax rate (controlling interest) in 2021 is higher than the marginal tax rate, primarily due to non-deductible compensation expense and an increase in deferred tax expense resulting from the revaluation of certain deferred tax liabilities due to an increase in the UK tax rate enacted during 2021. The effective tax rate (controlling interest) in 2022 is lower than the marginal rate primarily due to the tax benefits of foreign operations and a state tax benefit related to the BPEA Transaction. The effective tax rate (controlling interest) in 2023 is lower than the marginal rate primarily due to discrete benefits from foreign operations.
Deferred income tax liability (net) reflects the expected future tax consequences of temporary differences between the financial reporting bases and tax bases of the Company’s assets and liabilities. The significant components of the Company’s Deferred income tax liability (net) are as follows:
 December 31,
 20222023
Deferred Tax Assets  
Deferred compensation$14.6 $15.9 
State loss carryforwards16.4 14.7 
Foreign loss carryforwards20.0 19.8 
Tax benefit of uncertain tax positions12.6 10.0 
Lease liabilities6.6 4.8 
Foreign tax credits15.4 16.0 
Other0.3 0.3 
Total deferred tax assets85.9 81.5 
Valuation allowance(48.1)(47.6)
Deferred tax assets, net of valuation allowance$37.8 $33.9 
Deferred Tax Liabilities  
Intangible asset amortization$(280.9)$(295.8)
Non-deductible intangible amortization(109.8)(97.0)
Junior convertible securities interest(72.4)(83.1)
Right-of-use assets(5.1)(3.7)
Accrued expenses(3.0)(2.0)
Deferred income(23.4)(10.4)
Other(4.4)(2.9)
Total deferred tax liabilities(499.0)(494.9)
Deferred income tax liability (net)(1)
$(461.2)$(461.0)
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(1)As of December 31, 2022 and 2023, foreign loss carryforwards of $20.0 million (net of a $16.5 million valuation allowance) and $19.8 million (net of a $17.0 million valuation allowance), respectively, are included in Other assets as they represent a net deferred tax asset in a foreign jurisdiction.
As of December 31, 2023, the Company had available state net operating loss carryforwards of $228.2 million, a majority of which will expire over six years to 11 years. As of December 31, 2023, the Company had foreign loss carryforwards of $74.8 million, of which $57.5 million will expire over nine years to 16 years and $17.3 million will carry forward indefinitely. As of December 31, 2023, the Company had foreign tax credit carryforwards of $16.0 million, a majority of which will expire over five years to eight years.
The Company believed it was more-likely-than-not that the benefit from certain state and foreign loss carryforwards and foreign tax credit carryforwards would not be fully realized, and, as of December 31, 2023, had valuation allowances of $14.6 million, $17.0 million, and $16.0 million on the state and foreign loss carryforwards and the foreign tax credit carryforwards, respectively. For the years ended December 31, 2022 and 2023, the Company increased its valuation allowance $4.2 million and $0.5 million, respectively.
The Company’s estimates and assumptions regarding the realization of its state and foreign loss carryforwards do not contemplate certain changes in ownership of the Company’s stock which could limit the utilization of these carryforwards.
The Company provides for U.S. income taxes on all foreign earnings. The Company does not provide for U.S. income taxes on the portion of the excess of the financial reporting bases over tax bases in the Company’s investments in foreign subsidiaries considered permanent in duration. Such amount would generally become taxable upon the repatriation of assets from, or a sale or liquidation of, the foreign subsidiaries. While a determination of the potential amount of unrecognized deferred U.S. income tax liability related to these amounts is not practicable because of the numerous assumptions associated with this hypothetical calculation, as of December 31, 2023, the estimated amount of such difference was $347.7 million.
A reconciliation of the changes in unrecognized tax benefits is as follows:
 For the Years Ended December 31,
 202120222023
Balance, beginning of period$63.5 $52.4 $49.6 
Additions based on current year tax positions0.8 0.6 6.4 
Additions based on prior years’ tax positions4.6 4.4 1.0 
Reduction for prior years’ tax positions(5.6)(1.0)(13.5)
Lapse of the statute of limitations(5.7)(5.5)(4.8)
Settlements(5.5)— (1.3)
Foreign currency translation0.3 (1.3)0.4 
Balance, end of period$52.4 $49.6 $37.8 
Included in the balance of unrecognized tax benefits as of December 31, 2021, 2022, and 2023 were $52.4 million, $49.6 million, and $37.8 million, respectively, of tax benefits that, if recognized, would favorably affect the Company’s effective tax rate (controlling interest). As of December 31, 2023 certain of these benefits, if realized, would be offset by the utilization of indirect tax benefits, for which the Company has accrued deferred tax assets of $10.0 million.
The Company records accrued interest and penalties, if any, related to unrecognized tax benefits in Income tax expense. For the years ended December 31, 2021, 2022, and 2023 interest and penalties related to unrecognized tax benefits were $(0.4) million, $2.6 million, and $0.8 million, respectively. As of December 31, 2022 and 2023, the Company accrued interest and penalties related to unrecognized tax benefits of $13.6 million and $14.4 million, respectively.
The Company is subject to U.S. federal, state and local, and foreign income tax in multiple jurisdictions and is periodically subject to tax examinations in these jurisdictions. The completion of examinations may result in the payment of additional taxes and/or the recognition of tax benefits. The Company is generally no longer subject to income tax examinations by U.S. federal, state and local, or foreign taxing authorities for periods prior to 2017.
In August 2022, the Inflation Reduction Act was enacted into law and included provisions for a 15% corporate alternative minimum income tax and a 1% excise tax on repurchases of the Company’s common stock. These provisions, which were effective for the Company beginning January 1, 2023, did not have a material impact on the Company’s Consolidated Financial Statements for the year ended December 31, 2023. The Company records the excise tax as part of the cost basis of its common stock repurchased.