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Income Taxes (Tables)
12 Months Ended
Dec. 31, 2023
Income Tax Disclosure [Abstract]  
Income Before Income Tax Provision (Benefit)
Our income before income taxes was subject to taxes in the following jurisdictions for the following periods (in millions):
Years Ended December 31,
202320222021
United States$3.5 $97.8 $295.3 
Foreign31.3 44.1 55.3 
Total$34.8 $141.9 $350.6 
Expense (Benefit) for Income Taxes
The provision (benefit) for income taxes is comprised of (in millions):
Years Ended December 31,
202320222021
Current tax provision:
Federal$7.0 $9.8 $2.9 
State7.1 5.7 2.3 
Foreign6.8 6.4 14.6 
20.9 21.9 19.8 
Deferred tax provision (benefit):
Federal(36.3)(42.6)11.0 
State(37.0)7.9 7.2 
Foreign(7.8)(3.2)(9.4)
(81.1)(37.9)8.8 
Income tax (benefit) provision$(60.2)$(16.0)$28.6 
Components of Deferred Tax Assets and Liabilities
Significant components of our deferred tax assets and liabilities as of December 31, 2023 and 2022 are as follows (in millions):
December 31,
20232022
Deferred tax assets:
Operating loss carryforwards$132.3 $135.9 
Tax credit carryforwards58.7 57.3 
ASC Topic 842 lease liability461.1 441.6 
Deemed landlord financing252.3 167.5 
Other103.9 90.3 
Total deferred tax assets1,008.3 892.6 
Valuation allowance for deferred tax assets(47.7)(100.2)
Deferred tax assets, net of valuation allowance960.6 792.4 
Deferred tax liabilities:
Basis difference related to fixed assets(209.9)(146.6)
Basis difference related to intangible assets with an indefinite life(337.1)(332.4)
ASC Topic 842 ROU assets(425.3)(414.7)
Other(9.3)(0.1)
Total deferred tax liabilities(981.6)(893.8)
Net deferred tax assets (liabilities) are shown on the accompanying consolidated balance sheets as follows:
Non-current deferred tax assets15.7 16.1 
Non-current deferred tax liabilities (36.7)(117.5)
Deferred tax liabilities, net$(21.0)$(101.4)
Credit Carryforward Expiry
As of December 31, 2023, we had federal and state income tax credit carryforwards of $46.6 million and $33.7 million, respectively, which will expire if unused at various dates beginning on December 31, 2028. Such carryforwards expire as follows (in millions):
U.S. foreign tax credit$2.2 2028-2033
U.S. business tax credits$44.4 2030-2043
State business tax credits - indefinite lived$29.4 Do not expire
State business tax credits - definite lived$4.3 2032-2047
Net Operating Losses Expiry
As of December 31, 2023, we had federal, Germany, and United Kingdom net operating losses (“NOLs”) carryforwards of $389.3 million and interest expense carryforwards of $49.9 million, respectively. Such carryforwards expire as follows (in millions):
U.S. loss carryforwards - definite lived$14.7  2028-2037
U.S. loss carryforwards - indefinite lived$179.2  Do not expire
U.S. interest expense carryforwards$49.9  Do not expire
Germany loss carryforwards$110.8 Do not expire
United Kingdom loss carryforwards$84.6 Do not expire
Reconciliation of Effective Tax Rate on Income or Loss and Statutory Tax Rate
A reconciliation of the effective tax rate on income or loss and the statutory tax rate is as follows:
Years Ended December 31,
202320222021
Statutory U.S. tax rate21.0 %21.0 %21.0 %
State income taxes, net of U.S. tax benefit(67.7)%7.1 %2.1 %
Foreign income taxed at other than U.S. statutory rate(26.0)%(8.9)%(3.3)%
Federal tax credits(46.6)%(8.7)%(2.0)%
Revaluation of Company stock attributable to Topgolf merger— %— %(15.1)%
Other non-deductible expenses6.0 %1.0 %0.7 %
Non-deductible compensation17.9 %4.5 %1.4 %
U.S. Foreign tax inclusion0.4 %1.0 %0.5 %
Foreign derived intangible income deduction(7.5)%(3.0)%(2.1)%
Stock compensation excess tax benefits— %— %(1.6)%
Impact of uncertain tax positions8.5 %(0.8)%(2.2)%
Change in deferred tax valuation allowance(88.5)%(23.0)%7.8 %
Withholding tax impacts on foreign subsidiaries5.5 %— %— %
Other4.3 %(1.5)%1.0 %
Effective tax rate(172.7)%(11.3)%8.2 %
Reconciliation of Unrecognized Tax Benefits
A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows (in millions):
202320222021
Balance at January 1$26.2 $26.6 $28.3 
Additions based on tax positions related to the current year1.8 1.7 1.7 
Additions for tax positions of prior years2.0 1.2 0.5 
Reductions for tax positions of prior years— (1.5)(0.9)
Settlement of tax audits— — (2.7)
Current year acquisitions— — 6.7 
Reductions due to lapsed statute of limitations(0.7)(1.8)(7.0)
Balance at December 31$29.3 $26.2 $26.6 
Major Jurisdictions No Longer Subject to Income Tax Examinations by Tax Authorities
We or one of our subsidiaries files income tax returns in the U.S. federal jurisdiction and various U.S. states and foreign jurisdictions. We are generally no longer subject to income tax examinations by tax authorities in our major jurisdictions as follows:
Major Tax JurisdictionYears No Longer Subject to Audit
U.S. Federal2010 and prior
Germany2013 and prior
Japan2017 and prior
South Korea2021 and prior
United Kingdom2018 and prior