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Income Taxes
 12 Months Ended
Dec. 31, 2023
Income Taxes  
Income Taxes


The sources of income before income taxes for the years ended December 31, 2023, 2022 and 2021 are presented as follows:


Year Ended December 31,

(in millions)


2023


2022


2021

Income before taxes:







United States


$

7.0


$

(12.5

 )


$

(4.8

 )

Foreign


393.4


335.1


140.4

Total income before income taxes


$

400.4



$

322.6



$

135.6



The Company's income tax expense for the years ended December 31, 2023, 2022 and 2021 consisted of the following:


Year Ended December 31,

(in millions)


2023


2022


2021

Current tax expense (benefit):







U.S.


$

5.1


$

3.9


$

2.8

Foreign


102.9



80.3



59.9


Total current


108.0



84.2



62.7


Deferred tax expense (benefit):










U.S.


12.2


(7.3

 )


12.3

Foreign


0.7


15.0


(9.9

 )

Total deferred


12.9



7.7


2.4

Total tax expense


$

120.9



$

91.9



$

65.1


The following is a reconciliation of the federal statutory income tax rates of 21% to the effective income tax rate for the years ended December 31, 2023, 2022 and 2021:


Year Ended December 31,

(dollar amounts in millions)


2023


2022


2021

U.S. federal income tax expense at applicable statutory rate


$

84.1



$

67.7



$

28.5


Tax effect of:










State income tax expense at statutory rates, net of U.S. federal income tax


3.7



3.7



1.5


Non-deductible expenses


2.9



1.7



0.5


Share-based compensation


4.0


1.9



(3.5

)

Other permanent differences


0.9


(0.2

 )


(2.0

 )

Difference between U.S. federal and foreign tax rates


16.7



13.9



7.4

Provision in excess of statutory rates


8.3


3.6



2.9

Change in federal and foreign valuation allowance


2.7


(7.7

 )


26.7

GILTI, net of tax credits


5.9



9.8



3.9


Tax credits


(9.2

 )


(0.7

 )


(1.1

 )

Other


0.9


(1.8

 )


0.3


Total income tax expense


$

120.9



$

91.9



$

65.1


Effective tax rate


30.19

%


28.47

%


48.00

%


We calculate our provision for federal, state and foreign income taxes based on current tax law.


The tax effect of temporary differences and carryforwards that give rise to deferred tax assets and liabilities from continuing operations are as follows:


As of December 31,

(in millions)


2023


2022

Deferred tax assets:





Tax loss carryforwards


$

59.3



$

64.9


Share-based compensation


15.8



12.6


Accrued expenses


20.1



23.2


Property and equipment


8.1



10.8


Goodwill and intangible amortization


11.2



9.0


Contract costs
3.5

7.0

Intercompany notes


16.7



17.4


Accrued revenue


4.0



5.1


Tax credits


58.1



64.4


Lease accounting


49.2



40.2


Foreign exchange
2.4

2.7
Capitalized research and development
6.2

—

Other


6.0



7.8


Total deferred tax assets


260.6



265.1


Valuation allowance


(90.7 )


(90.4

)

Total deferred tax assets, net of valuation allowance


169.9



174.7


Deferred tax liabilities:







Intangible assets related to purchase accounting


(15.0

 )


(12.1

)

Goodwill and intangible amortization


(31.9

 )


(31.7

)

Accrued expenses


(25.7

 )


(22.7

)

Intercompany notes


(12.9

 )


(14.5

)

Accrued interest


(34.4

 )


(26.6

)

Capitalized research and development


(0.3

 )


(1.2

)

Property and equipment


(6.8

 )


(14.6

)

Accrued revenue


(2.8

 )


(2.1

)

Lease accounting


(49.2

 )


(40.2

)

Foreign exchange
(4.0 )
(9.8 )

Other


(5.6

 )


(3.5

)

Total deferred tax liabilities


(188.6

 )


(179.0

)

Net deferred tax liabilities


$

(18.7

 )


$

(4.3

)


Subsequently recognized tax benefits relating to the valuation allowance for deferred tax assets as of December 31, 2023 are expected to be allocated to income taxes in the Consolidated Statements of Operations. As of December 31, 2023, and 2022, the Company's foreign tax loss carryforwards were $247.4 million and $260.6 million, respectively, and U.S. state tax loss carryforwards were $68.4 million and $97.7 million, respectively.


As of December 31, 2023, the Company had U.S. foreign tax credit carryforwards of $53.6 million which are largely not expected to be utilized in future periods. As of December 31, 2022, the Company had U.S. foreign tax credit carryforwards of $59.8 million which are largely not expected to be utilized in future periods.


In assessing the Company's ability to realize deferred tax assets, management considers whether it is more likely than not that some portion or all of the deferred tax assets will not be realized. The ultimate realization of deferred tax assets is dependent upon the generation of future taxable income during the periods in which those temporary differences become deductible. Management considers the scheduled reversal of deferred tax liabilities, projected future taxable income and tax planning strategies in making this assessment. Based upon the level of historical taxable income and projections for future taxable income over the periods in which the deferred tax assets are deductible, management believes it is more likely than not the Company will realize the benefits of these deductible differences, net of the existing valuation allowances, as of December 31, 2023.


As of December 31, 2023, the Company had foreign tax net operating loss carryforwards of $247.4 million, which will expire as follows:


(in millions)


Gross


Tax Effected

Year ending December 31,





2024


$

1.7



$

0.4


2025


13.1



3.3


2026


18.3



4.6


2027


3.6



0.9


2028


4.1



1.0


Thereafter


20.3



5.3


Unlimited


186.3



42.2


Total


$

247.4



$

57.7



In addition, the Company's state tax net operating loss carryforwards of $68.4 million will expire periodically from 2024 through 2043, U.S. foreign tax credit carryforwards of $53.6 million will expire periodically from 2027 through 2032 and U.S. federal research and expenditure credit carryforwards of $3.8 million will expire periodically from 2034 through 2042.


The Company has not provided additional deferred taxes with respect to items such as certain foreign exchange gains or losses, foreign withholding taxes or additional state taxes, if any, on undistributed earnings attributable to foreign subsidiaries and it is not practical to determine the income tax liability that would be payable if such earnings were not reinvested indefinitely. Gross undistributed earnings reinvested indefinitely in foreign subsidiaries aggregated approximately $2,356.1 million as of December 31, 2023.


Accounting for uncertainty in income taxes


A reconciliation of the beginning and ending amount of unrecognized tax benefits for the years ended December 31, 2023 and 2022 is as follows:




Year Ended December 31,

(in millions)


2023


2022

Beginning balance


$

42.8



$

41.0


Additions based on tax positions related to the current year


7.2



6.1


Additions for tax positions of prior years


2.6



0.3


Reductions for tax positions of prior years


(0.1

 )


(4.0

)

Statute of limitations expiration


(0.7

 )


(0.6

)

Ending balance


$

51.8



$

42.8



As of December 31, 2023 and 2022, approximately $38.2 million and $30.8 million, respectively, of the unrecognized tax benefits would impact the Company's provision for income taxes and effective income tax rate, if recognized. Total estimated accrued interest and penalties related to the underpayment of income taxes was $10.0 million and $8.3 million as of December 31, 2023 and 2022, respectively. The following income tax years remain open in the Company's major jurisdictions as of December 31, 2023:


Jurisdictions

Periods

U.S. (Federal)

2014 through 2023

Germany

2016 through 2023

Greece

2013 through 2023

Spain

2016 through 2023

U.K.

2019 through 2023


It is reasonably possible that the balance of gross unrecognized tax benefits could significantly change within the next twelve months as a result of the resolution of audit examinations and expirations of certain statutes of limitations and, accordingly, materially affect the Company's operating results. At this time, it is not possible to estimate the range of change due to the uncertainty of potential outcomes.