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Income Taxes | 12 Months Ended
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Dec. 31, 2025
Income Tax Disclosure [Abstract] |
Income Taxes | Income Taxes Income (loss) from continuing operations before income taxes consisted of the following:
| Years Ended December 31,
| 2025 |  | 2024 |  | 2023
U.S. | $ | 146,384 |  |  | $ | (112,261) |  |  | $ | (112,437) |
International | 46,140 |  |  | 59,934 |  |  | 68,517 |
Total | $ | 192,524 |  |  | $ | (52,327) |  |  | $ | (43,920) |
The provision (benefit) for income taxes consisted of the following:
| Years Ended December 31,
| 2025 |  | 2024 |  | 2023
U.S. Federal: |  |  |  |  |
Current | $ | (9,440) |  |  | $ | 2,535 |  |  | $ | 32,784 |
Deferred | 28,050 |  |  | (138,444) |  |  | (31,591) |
| 18,610 |  |  | (135,909) |  |  | 1,193 |
U.S. State and Local: |  |  |  |  |
Current | 2,912 |  |  | 1,375 |  |  | 9,083 |
Deferred | 7,368 |  |  | (41,416) |  |  | (9,973) |
| 10,280 |  |  | (40,041) |  |  | (890) |
International: |  |  |  |  |
Current | 15,950 |  |  | 14,971 |  |  | 11,266 |
Deferred | 2,987 |  |  | 6,150 |  |  | 5,778 |
| 18,937 |  |  | 21,121 |  |  | 17,044 |
Total current | 9,422 |  |  | 18,881 |  |  | 53,133 |
Total deferred | 38,405 |  |  | (173,710) |  |  | (35,786) |
Total provision (benefit) for income taxes | $ | 47,827 |  |  | $ | (154,829) |  |  | $ | 17,347 |
Effective tax rate | 24.8 | % |  | 295.9 | % |  | (39.5) | %
The benefit for income taxes for 2024 includes a tax benefit of $164 million primarily due to an affiliate reorganization as well as a $6 million benefit related to a state interest valuation allowance release. The effective tax rate for 2023 includes a benefit of $2 million on the aggregate $124 million goodwill impairment charge as the majority of this charge is nondeductible. In the fourth quarter of 2025, we prospectively adopted ASU 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures. A reconciliation of income taxes computed at the federal statutory rate and our provision or benefit for income taxes consisted of the following:
| Years Ended December 31,
| 2025 |  | 2024 |  | 2023
U.S. Federal statutory tax rate | $ | 40,430 |  | 21.0% |  | $ | (10,989) |  |  |  | $ | (9,223) |  |
State and local income taxes, net of federal benefit (1) | 8,126 |  | 4.2% |  | (31,632) |  |  |  | (703) |  |
Foreign tax effects |  |  |  |  |  |  |  |
Canada |  |  |  |  |  |  |  |
Capital gain | 4,381 |  | 2.3% |  |  |  |  |  |
Other | (550) |  | (0.3)% |  |  |  |  |  |
Other foreign jurisdictions | 5,131 |  | 2.7% |  |  |  |  |  |
Impact of foreign operations taxed at rates other than the U.S. statutory rate (2) |  |  |  | 4,595 |  |  |  | 2,779 |  |
Effect of cross-border tax laws |  |  |  |  |  |  |  |
Global intangible low-taxed income | 566 |  | 0.3% |  |  |  |  |  |
Subpart F income | 2,009 |  | 1.0% |  |  |  |  |  |
Other | (489) |  | (0.3)% |  |  |  |  |  |
U.S. tax impacts of foreign income in the U.S. (3) |  |  |  | 7,983 |  |  |  | 1,099 |  |
Changes in valuation allowances | — |  |  |  | 2,100 |  |  |  | — |  |
Nontaxable or nondeductible items |  |  |  |  |  |  |  |
Unrealized stock compensation benefits | (2,057) |  | (1.1)% |  | 1,686 |  |  |  | 574 |  |
Surrender of company-owned life insurance policies | — |  |  |  | 8,139 |  |  |  | — |  |
Nondeductible officer's compensation | 5,123 |  | 2.7% |  | 5,992 |  |  |  | — |  |
Affiliate reorganization | — |  |  |  | (141,723) |  |  |  | — |  |
Goodwill impairment | — |  |  |  | — |  |  |  | 24,437 |  |
Changes in unrecognized tax benefits |  |  |  |  |  |  |  |
Accrual/release of uncertain tax amounts related to foreign operations (4) | (14,328) |  | (7.4)% |  | (829) |  |  |  | (2,829) |  |
Other adjustments | (515) |  | (0.3)% |  | (151) |  |  |  | 1,213 |  |
Provision (benefit) for income taxes | $ | 47,827 |  | 24.8% |  | $ | (154,829) |  |  |  | $ | 17,347 |  |
(1) State taxes in California, Illinois, New York and New Jersey make up the majority (greater than 50%) of the tax effect in this category for the year ended December 31, 2025. Also includes a benefit of $22 million related to the affiliate reorganization and a benefit of $6 million related to a state interest valuation allowance release for the year ended December 31, 2024. (2) Includes a charge of $1 million for a change in tax rates for the year ended December 31, 2024. (3) Includes a charge of $2 million for the loss of the GILTI deduction as well as a charge of $2 million for withholding tax for the year ended December 31, 2024. (4) Includes a benefit of $4 million related to interest on unrecognized tax benefits for the year ended December 31, 2025. Deferred tax liabilities and assets consisted of the following:
| December 31,
| 2025 |  | 2024
Deferred tax liabilities: |  |  |
Deferred profit (for tax purposes) on sale to finance subsidiary | $ | (44,759) |  |  | $ | (53,370) |
Lease revenue and related depreciation | (167,126) |  |  | (183,237) |
Intangible assets | (53,334) |  |  | (52,773) |
Operating lease liability | (26,135) |  |  | (27,857) |
Other | (12,208) |  |  | (10,847) |
Gross deferred tax liabilities | (303,562) |  |  | (328,084) |
Deferred tax assets: |  |  |
Depreciation | 9,314 |  |  | 32,539 |
Postretirement medical benefits | 18,949 |  |  | 20,108 |
Pension | 16,610 |  |  | 16,948 |
Operating lease asset | 31,411 |  |  | 31,429 |
Long-term incentives | 3,773 |  |  | 5,914 |
Net operating and capital losses | 248,099 |  |  | 257,186 |
Tax credit carry forwards | 67,376 |  |  | 65,697 |
Section 163j carryforward | 76,309 |  |  | 86,075 |
Tax uncertainties gross-up | 3,379 |  |  | 4,568 |
Other | 63,387 |  |  | 57,915 |
Gross deferred tax assets | 538,607 |  |  | 578,379 |
Less: Valuation allowance | (224,922) |  |  | (206,441) |
Net deferred tax assets | 313,685 |  |  | 371,938 |
Total deferred taxes, net | $ | 10,123 |  |  | $ | 43,854 |
The valuation allowance relates primarily to certain foreign, state and local net operating loss and tax credit carryforwards that will more-likely-than-not expire without being utilized.
We have a federal net operating loss carryforward of $224 million as of December 31, 2025, that has an unlimited carryforward period. We have net operating loss carryforwards in international jurisdictions of $422 million as of December 31, 2025, of which $118 million can be carried forward indefinitely and the remainder expire over the next 20 years. We also have net operating loss carryforwards in most states totaling $1 billion that will expire over the next 20 years. In addition, we have tax credit carryforwards of $67 million, of which $52 million can be carried forward indefinitely and the remainder expire over the next 10 years. As of December 31, 2025, we assert that we are permanently reinvested in our pre-1987 and post-2017 undistributed earnings of $587 million as well as all other outside basis differences. While a determination of the full liability that would be incurred if these earnings were repatriated is not practicable, we have estimated the withholding taxes would be approximately $3 million. A reconciliation of the amount of unrecognized tax benefits is as follows:
| Years Ended December 31,
| 2025 |  | 2024 |  | 2023
Balance at beginning of year | $ | 27,037 |  |  | $ | 30,232 |  |  | $ | 33,300 |
Increases from prior period positions | — |  |  | — |  |  | 343 |
Decreases from prior period positions | (39) |  |  | (955) |  |  | (524) |
Increases from current period positions | — |  |  | 73 |  |  | 400 |
Decreases relating to settlements with tax authorities | (52) |  |  | (1,467) |  |  | (350) |
Reductions from lapse of applicable statute of limitations | (10,845) |  |  | (846) |  |  | (2,937) |
Balance at end of year | $ | 16,101 |  |  | $ | 27,037 |  |  | $ | 30,232 |
The amount of the unrecognized tax benefits at December 31, 2025, 2024 and 2023 that would affect the effective tax rate if recognized was $13 million, $24 million and $26 million, respectively. We recognize interest and penalties related to uncertain tax positions in our provision for income taxes. The amount included in our provision for income taxes related to interest and penalties on uncertain tax positions for the year ended December 31, 2025 was a benefit of $4 million and for each of the years ended December 31, 2024 and 2023 were not significant. We had approximately $4 million accrued for the payment of interest and penalties at December 31, 2024. Cash income tax payments, net of refunds consisted of the following:
| Year Ended December 31, 2025
Federal | $ | (6,836) |  |  |  |  |
State |  |  |  |  |
California | 1,480 |  |  |  |  |
Other | 1,717 |  |  |  |  |
Foreign |  |  |  |  |
Barbados | 1,678 |  |  |  |  |
Canada | 9,828 |  |  |  |  |
France | 3,595 |  |  |  |  |
Japan | 2,097 |  |  |  |  |
Other | 2,500 |  |  |  |  |
Cash income tax payments, net of refunds | $ | 16,059 |  |  |  |  |
Cash income tax payments, net of refunds for the years ended December 31, 2024 and 2023 were $45,478 and $22,626, respectively. Other Tax Matters The One Big Beautiful Bill Act that was enacted on July 4, 2025, did not have a material impact on our tax provision. With regard to U.S. Federal income tax, all positions are effectively settled with the Internal Revenue Service for years prior to 2022. On a state and local level, returns for most jurisdictions are closed through 2019. For our significant non-U.S. jurisdictions, Canada is closed to examination through 2020 except for a specific issue under current exam, and France, Germany and the U.K. are closed through 2019, 2020, and 2023 respectively. We also have other less significant tax filings currently subject to examination, including an appeal of a specific issue in India. We regularly assess the likelihood of tax adjustments in each of the tax jurisdictions in which we have operations and account for the related financial statement implications. We believe we have established tax reserves that are appropriate given the possibility of tax adjustments. However, determining the appropriate level of tax reserves requires judgment regarding the uncertain application of tax law and the possibility of tax adjustments. Future changes in tax reserve requirements could have a material positive or negative impact on our results of operations, financial position and cash flows.

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