Income Taxes (Tables)
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12 Months Ended |
Dec. 31, 2021 |
Income Tax Disclosure [Abstract] |
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Consolidated Income Loss Before Taxes for Domestic and Foreign |
Consolidated income (loss) before taxes for United States ("U.S.") and foreign operations consisted of the following (in thousands): | | | | | | | | | | | | | | | | | | | Years Ended December 31, | | 2021 | | 2020 | | 2019 | United States | $ | (264,323) | | | $ | (821,012) | | | $ | (158,937) | | Foreign | (747,193) | | | (941,263) | | | 647,155 | | Total | $ | (1,011,516) | | | $ | (1,762,275) | | | $ | 488,218 | |
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Provision (Benefit) for Income Taxes |
The income tax provision (benefit) attributable to income before income taxes is as follows (in thousands): | | | | | | | | | | | | | | | | | | | December 31, | | 2021 | | 2020 | | 2019 | Current | | | | | | U.S. Federal | $ | — | | | $ | (2) | | | $ | (14) | | U.S. State | — | | | 309 | | | 868 | | Foreign | 2,746 | | | 1,879 | | | 1,796 | | Total | 2,746 | | | 2,186 | | | 2,650 | | Deferred | | | | | | U.S. Federal | (176) | | | 563,658 | | | 170,508 | | U.S. State | (20) | | | (1,095) | | | 3,682 | | Foreign | (2,076) | | | (78) | | | — | | Total | (2,272) | | | 562,485 | | | 174,190 | | Total income tax provision (benefit) | $ | 474 | | | $ | 564,671 | | | $ | 176,840 | |
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Income Taxes (Federal Statutory Corporate Tax Rate) |
The reconciliation of the U.S. federal statutory tax rate to the actual tax rate is as follows: | | | | | | | | | | | | | | | | | | | December 31, | | 2021 | | 2020 | | 2019 | U.S. Federal statutory rate | 21.0 | % | | 21.0 | % | | 21.0 | % | State Tax | 1.6 | % | | — | % | | — | % | Foreign tax credits, net of valuation allowance | 0.7 | % | | (31.8) | % | | 13.1 | % | Non-taxable foreign income | (3.0) | % | | (2.2) | % | | (27.4) | % | Foreign tax rate differential | (9.4) | % | | (5.3) | % | | (10.4) | % | Global intangible low-taxed income | — | % | | — | % | | 10.1 | % | Valuation allowance, other | (6.8) | % | | (11.1) | % | | 20.6 | % | Other, net | (4.1) | % | | (2.6) | % | | 9.2 | % | Effective income tax rate | — | % | | (32.0) | % | | 36.2 | % |
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Net Deferred Tax Assets and Liabilities |
The tax effects of significant temporary differences representing net deferred tax assets and liabilities consisted of the following (in thousands): | | | | | | | | | | | | | December 31, | | 2021 | | 2020 | Deferred tax assets—U.S.: | | | | Foreign tax credit carryforwards | $ | 2,000,145 | | | $ | 2,540,400 | | Disallowed interest expense carryforward | 154,530 | | | 138,339 | | Net operating loss carryforward | 89,665 | | | 45,015 | | Lease liability | 22,021 | | | 22,826 | | Property and Equipment | 28,710 | | | 3,048 | | Receivables, inventories, accrued liabilities and other | 21,714 | | | 25,882 | | Stock-based compensation | 12,488 | | | 7,528 | | Other tax credit carryforwards | 10,784 | | | 10,049 | | Intangibles and related other | 28,038 | | | 50,750 | | Other | 553 | | | 5,502 | | | 2,368,648 | | | 2,849,339 | | Less: valuation allowance | (2,329,495) | | | (2,812,808) | | | 39,153 | | | 36,531 | | Deferred tax liabilities—U.S.: | | | | Property and equipment | (1,217) | | | — | | Lease asset | (22,021) | | | (22,826) | | Prepaid insurance, maintenance and taxes | (14,271) | | | (13,606) | | Other | (1,749) | | | (400) | | | (39,258) | | | (36,832) | | Deferred tax assets—Foreign: | | | | Net operating loss carryforwards | 99,873 | | | 107,653 | | Property and equipment | 69,166 | | | 61,428 | | Pre-opening expenses | 1,536 | | | 3,832 | | Other | 6,060 | | | 6,529 | | | 176,635 | | | 179,442 | | Less: valuation allowance | (171,768) | | | (173,876) | | | 4,867 | | | 5,566 | | Deferred tax liabilities—Foreign: | | | | Property and equipment | (3,352) | | | (4,234) | | Intangibles | (77) | | | (2,402) | | | (3,429) | | | (6,636) | | | | | | Net deferred tax asset (liability) | $ | 1,333 | | | $ | (1,371) | |
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Summary of Valuation Allowances |
As of December 31, 2021 and 2020, the Company had valuation allowances provided on its deferred tax assets as follows (in thousands): | | | | | | | | | | | | | December 31, | | 2021 | | 2020 | Foreign tax credits | $ | 2,000,145 | | | $ | 2,540,400 | | Disallowed interest expense carryforwards | 154,530 | | | 138,339 | | Intangible assets | 29,081 | | | 48,395 | | U.S. loss carryforwards | 89,665 | | | 45,015 | | Other U.S. deferred tax assets | 56,073 | | | 40,659 | | Foreign loss carryforwards | 99,971 | | | 106,737 | | Other foreign deferred tax assets | 71,798 | | | 67,139 | | Total | $ | 2,501,263 | | | $ | 2,986,684 | |
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Reconciliation of Unrecognized Tax Benefits |
The Company had the following activity for unrecognized tax benefits as follows (in thousands): | | | | | | | | | | | | | | | | | | | December 31, | | 2021 | | 2020 | | 2019 | Balance at beginning of period | $ | 107,661 | | | $ | 104,295 | | | $ | 99,470 | | Increases based on tax positions of the current year | 14,079 | | | 7,061 | | | 8,986 | | Increases based on tax positions of prior years | 66,043 | | | — | | | — | | Reductions based on tax positions of prior years | (35,633) | | | — | | | — | | Reductions due to lapse in statutes of limitations | (10,635) | | | (3,695) | | | (4,161) | | Balance at end of period | $ | 141,515 | | | $ | 107,661 | | | $ | 104,295 | |
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