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Income Taxes
3 Months Ended
Mar. 31, 2023
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
We calculate our interim income tax provision in accordance with Accounting Standards Codification (“ASC”) Topic 270, “Interim Reporting,” and ASC Topic 740, “Accounting for Income Taxes.” At the end of each interim period, we estimate our annual effective tax rate and apply that rate to our ordinary quarterly earnings to calculate the tax related to ordinary income. The tax effects for other items that are excluded from ordinary income are discretely calculated and recognized in the period in which they occur.
The realization of deferred tax assets, including loss and credit carryforwards, is subject to us generating sufficient taxable income during the periods in which the deferred tax assets become realizable. As a result of the Topgolf merger and the fact that Topgolf’s losses exceed our income in recent years, we have determined that it is not more likely than not that a portion of our U.S. deferred tax assets will be realized. The valuation allowance on our U.S. deferred tax assets as of March 31, 2023, primarily relate to federal and state deferred tax assets related to tax attributes that we estimate are not more likely than not to be utilized prior to expiration. However, if our more recent earnings history were to continue, management believes that it is possible that within the next 12 months sufficient positive evidence may become available to allow management to reach a conclusion that a significant portion of the valuation allowance will no longer be needed. Release of the valuation allowance would result in the recognition of certain deferred tax assets with a potential corresponding decrease to income tax expense for the period the release is recorded, which would represent a non-cash benefit. The exact timing and amount of the valuation allowance release would be predicated on our continued profitability combined with the continued profitability we believe we can maintain. With respect to non-U.S. entities, there continues to be sufficient positive evidence to conclude that realization of our deferred tax assets is more likely than not under applicable accounting rules, and therefore no significant valuation allowances have been established.

We recorded an income tax benefit of $4.2 million and $15.7 million for the three months ended March 31, 2023 and 2022, respectively. As a percentage of pre-tax income, our effective tax rate was (20.0)% and (22.0)% for the three months ended March 31, 2023 and 2022, respectively. In the three months ended March 31, 2023 and 2022, the primary difference between the statutory rate and the effective rate relates to the release of valuation allowances on our deferred tax assets.
At March 31, 2023, the gross liability for income taxes associated with uncertain tax positions was $27.3 million. Of this amount, $10.9 million would benefit our condensed consolidated financial statements and effective income tax rate if favorably settled. We recognize interest and penalties related to income tax matters in income tax expense.