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INCOME TAXES | 12 Months Ended
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Dec. 31, 2024
Income Tax Disclosure [Abstract] |
INCOME TAXES | INCOME TAXES Our tax provision includes federal, state and foreign income taxes payable. The domestic and foreign components of our income before taxes and noncontrolling interests were as follows:
| Year Ended December 31,
($ in millions) | 2024 |  | 2023 |  | 2022
U.S. (loss) income before tax | $ | (61) |  |  | $ | 335 |  |  | $ | 384 |
Foreign income before tax | 197 |  |  | 114 |  |  | 97 |
Total income before taxes | $ | 136 |  |  | $ | 449 |  |  | $ | 481 |
The components of our provision for income taxes were as follows:
| Year Ended December 31,
($ in millions) | 2024 |  | 2023 |  | 2022
Current: |  |  |  |  |
Federal | $ | 23 |  |  | $ | 105 |  |  | $ | 102 |
State | 4 |  |  | 18 |  |  | 19 |
Foreign | 78 |  |  | 36 |  |  | 46 |
Total current | 105 |  |  | 159 |  |  | 167 |
Deferred: |  |  |  |  |
Federal | (18) |  |  | (22) |  |  | (21) |
State | (3) |  |  | (1) |  |  | (16) |
Foreign | (8) |  |  | — |  |  | (1) |
Total deferred | (29) |  |  | (23) |  |  | (38) |
Total provision for income taxes | $ | 76 |  |  | $ | 136 |  |  | $ | 129 |
Reconciliations of our tax provision at the U.S. statutory rate to the provision for income taxes were as follows:
| Year Ended December 31,
($ in millions) | 2024 |  | 2023 |  | 2022
Statutory U.S. federal income tax provision | $ | 29 |  |  | $ | 94 |  |  | $ | 101 |
State and local income taxes, net of U.S. federal tax benefit | 1 |  |  | 17 |  |  | 4 |
Taxes attributable to noncontrolling interest | (3) |  |  | — |  |  | — |
Impact of foreign operations | 27 |  |  | 10 |  |  | 17 |
Interest on installment sales, net of U.S. federal tax benefit | 4 |  |  | 3 |  |  | 1 |
Uncertain tax positions | 1 |  |  | 5 |  |  | 4 |
US permanent differences | 12 |  |  | 2 |  |  | — |
Share-based compensation, net of IRC §162(m) limitation | 3 |  |  | 2 |  |  | 3 |
Other | 2 |  |  | 3 |  |  | (1) |
Provision for income taxes | $ | 76 |  |  | $ | 136 |  |  | $ | 129 |
Deferred income taxes represent the tax effect of the differences between the book and tax bases of assets and liabilities plus carryforward items. The compositions of net deferred tax balances were as follows:
| December 31,
($ in millions) | 2024 |  | 2023
Deferred tax assets | $ | 12 |  |  | $ | 9 |
Deferred tax liabilities | (925) |  |  | (631) |
Net deferred tax liability | $ | (913) |  |  | $ | (622) |
The tax effects of the temporary differences and carryforwards that give rise to our net deferred tax liability were as follows:
| December 31,
($ in millions) | 2024 |  | 2023
Deferred tax assets: |  |  |
Compensation | $ | 30 |  |  | $ | 20 |
Domestic tax loss and credit carryforwards | 130 |  |  | 35 |
Foreign tax loss carryforwards | 44 |  |  | 41 |
Other reserves | 261 |  |  | 177 |
| 465 |  |  | 273 |
Valuation allowance | (174) |  |  | (81) |
Deferred tax assets | 291 |  |  | 192 |
Deferred tax liabilities: |  |  |
Property and equipment | (144) |  |  | (128) |
Amortizable intangible assets | (419) |  |  | (251) |
Deferred income | (641) |  |  | (435) |
Deferred tax liabilities | (1,204) |  |  | (814) |
Net deferred tax liability | $ | (913) |  |  | $ | (622) |
As of December 31, 2024, we have $276 million of federal net operating loss carryforwards, $20 million of federal credit carryforwards, $987 million of state tax net operating loss carryforwards, $6 million of state tax credits, and $170 million foreign net operating loss carryforwards. Most of these tax attributes are fully valued. The majority of our federal and state tax attributes will expire through 2034, while our foreign tax losses can be carried forward indefinitely. We establish valuation allowances for financial reporting purposes to offset certain deferred tax assets due to uncertainty regarding our ability to realize them in the future. The valuation allowance increased from $81 million as of December 31, 2023, to $174 million as of December 31, 2024, primarily due to acquired deferred tax assets from the Bluegreen Acquisition for which no future tax benefit is expected. Reconciliations of the amounts of unrecognized tax benefits were as follows:
| December 31,
($ in millions) | 2024 |  | 2023 |  | 2022
Unrecognized tax benefits at beginning of year | $ | 25 |  |  | $ | 23 |  |  | $ | 12 |
Current period tax position increases | 3 |  |  | 2 |  |  | 2 |
Prior period tax position increases | — |  |  | 3 |  |  | 11 |
Decreases due to lapse in applicable statute of limitations | (4) |  |  | (3) |  |  | (2) |
Unrecognized tax benefits at end of year | $ | 24 |  |  | $ | 25 |  |  | $ | 23 |
We recorded $24 million and $25 million as of December 31, 2024 and 2023, respectively, excluding interest and penalties, which would have favorably impacted the annual effective tax rate if recognized. We record these liabilities in Accounts payable, accrued expenses and other in the consolidated balance sheet. The total liability accrued for interest and penalties was $36 million and $34 million as of December 31, 2024, and 2023, respectively. We do not anticipate any significant increases or decreases in our unrecognized tax benefits within the next twelve months. We file federal, state and foreign income tax returns in jurisdictions with varying statute of limitations. We are currently under audit in several tax jurisdictions. The open tax years for major tax jurisdictions are 2006 through 2024. While there is no assurance as to the results, we believe we are adequately reserved for these audits. The Organization for Economic Co-operation and Development (“OECD”) has created a framework for the implementation of a global minimum tax rate of 15%, commonly referred to as Pillar Two. Certain countries in which we do business have enacted Pillar Two legislation effective January 1, 2024, however, Pillar Two legislation did not have a material impact to our income tax provision. Although the Tax Act generally eliminates U.S. federal income tax on dividends from foreign subsidiaries, foreign withholding taxes may be incurred if these profits are distributed. No income or deferred taxes have been accrued on foreign earnings or other outside basis differences, as we intend to indefinitely reinvest these amounts in our foreign operations. An estimate of these amounts is not practicable due to the inherent complexity of the multi-jurisdictional tax environment in which we operate.

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