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Income Taxes
 6 Months Ended
Jun. 30, 2025
Income Tax Disclosure [Abstract]  
Income Taxes
12. Income Taxes
Our income tax provision and the respective effective income tax rates are as follows (in millions, except for income tax rates):
For the Three Months Ended June 30,For the Six Months Ended June 30,
2025202420252024
Provision for income taxes$(109.6)$9.7 $(116.4)$13.0 
Effective income tax rate24.4 %8.3 %24.4 %8.8 %
Our provision for income taxes for the three months ended June 30, 2025 includes a net discrete income tax benefit of $12.3 million, of which a tax benefit of $17.4 million relates to the Watson Fuels sale and related asset impairment charges, partially offset by a net tax expense of $5.2 million related to return-to-provision adjustments and other changes in our reserves for uncertain tax positions.
Our provision for income taxes for the three months ended June 30, 2024 includes a net discrete income tax expense of $4.9 million, of which a tax expense of $9.1 million relates to the tax on gain on sale of Avinode and a tax expense of $1.6 million relates to return-to-provision adjustments, partially offset by a net tax benefit of $5.9 million primarily related to changes in our reserve for uncertain tax positions.
Our provision for income taxes for the six months ended June 30, 2025 includes a net discrete income tax benefit of $11.7 million, of which a tax benefit of $17.4 million relates to the Watson Fuels sale and related asset impairment charges and $3.6 million relates to changes in our reserves for uncertain tax positions and the resolution of various worldwide tax matters, partially offset by a tax expense of $2.6 million related to a valuation allowance recorded against the deferred tax assets of a foreign subsidiary and a net tax expense of $6.8 million related to return-to-provision and other adjustments.
Our provision for income taxes for the six months ended June 30, 2024 includes a net discrete income tax benefit of $0.2 million, of which a tax benefit of $8.4 million relates to changes in our reserve for uncertain tax positions and a tax benefit of $0.9 million relates to return-to-provision adjustments, partially offset by a net tax expense of $9.1 million related to the tax on gain on sale of Avinode.
Our income tax provisions for the three and six months ended June 30, 2025 and 2024 were calculated based on the estimated annual effective income tax rates for the 2025 and 2024 years, respectively. The actual effective income tax rate for the 2025 year may be materially different for several reasons including differences between estimated versus actual results and the geographic tax jurisdictions in which the results are earned.
On July 4, 2025, the One Big Beautiful Bill Act was enacted in the United States. These changes in tax laws may affect recorded deferred tax assets and liabilities and our effective tax rate in current and future periods. Management is currently evaluating the potential impact of this new legislation; however, we do not anticipate that the changes will have a material impact on our Condensed Consolidated Financial Statements.
We have various tax returns under examination both in the U.S. and foreign jurisdictions. The most material of these is in Denmark, where one of our subsidiaries has been under audit since 2018. Through June 30, 2025, we have received final tax assessments for the 2013 through 2019 tax years of approximately $124.6 million (DKK 788.7 million), and proposed tax assessments for the 2020 and 2021 tax years of approximately $27.1 million (DKK 171.5 million), excluding interest, which would be material. We believe we have substantial defenses to these assessments and expect to continue to pursue available administrative and judicial remedies to resolve this matter.
An unfavorable resolution of one or more of the above matters could have a material adverse effect on our operating results or cash flows in the quarter or year in which the adjustments are recorded, or the tax is due or paid. As examinations are still in process or have not yet reached the final stages of the appeals process, the timing of the ultimate resolution or payments that may be required cannot be determined at this time.