Income Taxes (Tables)

12 Months Ended

Dec. 31, 2015

Income Tax Disclosure [Abstract]

Schedule of Provision (Benefit) for Income Taxes

The components of the Company’s provision (benefit) for income taxes for the years ended December 31, 2015, 2014 and 2013, and a reconciliation of the U.S. federal statutory income tax rate to the Company’s effective tax rates for such years, are shown below.

	Year Ended December 31,
	2015			2014		2013
Current:
Federal	$	8,177		$	3,112	$	(3,678	)
Foreign		78,086			61,143		41,084
State and local (primarily UBT)		4,970			5,519		(167	)
Total current		91,233			69,774		37,239
Deferred:
Federal		(988,900	)		2,766		19,934
Foreign		(3,960	)		9,239		(4,520	)
State and local		(107,925	)		3,623		(960	)
Total deferred		(1,100,785	)		15,628		14,454
Total	$	(1,009,552	)	$	85,402	$	51,693

Schedule of Reconciliation of U.S. Federal Statutory Income Tax Rate to Effective Tax Rates

Year Ended December 31,
	2015			2014			2013
U.S. federal statutory income tax rate		35.0	%		35.0	%		35.0	%
Income of noncontrolling interests		13.8			(0.5	)		(0.8	)
Foreign source income not subject to U.S. income tax		419.4			(12.4	)		(12.7	)
Foreign taxes		(361.6	)		8.2			14.1
State and local taxes		522.2			1.8			2.6
Change in U.S. federal valuation allowance		5,477.0			(18.7	)		(14.9	)
Other, net		(31.5	)		3.0			0.5
Effective income tax rate (a)		6,074.3	%		16.4	%		23.8	%

(a) For the year ended December 31, 2015, the effective tax rate on “operating income (loss)” includes (i) the significant effect of the release of substantially all of our valuation allowance on deferred tax assets and the recognition of deferred tax assets associated with the recording of the tax receivable agreement obligation, as described below, and (ii) the negative impact on “operating income (loss)” as a result of the provision pursuant to the tax receivable agreement described below.

Schedule of Deferred Tax Assets and Liabilities

Details of the Company’s deferred tax assets and liabilities are as follows:

	December 31,
	2015			2014
Deferred Tax Assets:
Basis adjustments (a)	$	727,696		$	598,607
Compensation and benefits		204,780			258,976
Net operating loss and tax credit carryforwards		309,811			283,198
Depreciation and amortization		840			950
Other		36,154			36,470
Gross deferred tax assets		1,279,281			1,178,201
Valuation allowance		(89,251	)		(1,044,152	)
Deferred tax assets (net of valuation allowance)		1,190,030			134,049
Deferred Tax Liabilities:
Depreciation and amortization		17,629			21,908
Compensation and benefits		9,332			28,035
Goodwill		15,208			15,289
Other		28,370			39,705
Deferred tax liabilities		70,539			104,937
Net deferred tax assets	$	1,119,491		$	29,112

(a) The basis adjustments recorded as of December 31, 2015 and 2014 are primarily the result of additional basis from acquisitions of interests, including the impact of recording the tax receivable agreement obligation during the year ended December 31, 2015, discussed below.

Summary of Changes in Deferred Tax Assets Valuation Allowance

Changes in the deferred tax assets valuation allowance for the years ended December 31, 2015, 2014 and 2013 was as follows:

	Year Ended December 31,
	2015		2014			2013
Beginning Balance	$	1,044,152	$	1,225,305		$	1,238,765
Credited to provision (benefit) for income taxes (a)		(954,487)		(203,051	)		(35,470	)
Charged (credited) to other comprehensive income		(414)		21,898			22,010
Ending Balance	$	89,251	$	1,044,152		$	1,225,305

(a) Of the amount in 2014 of $203,051, approximately $106,000 is due primarily to the remeasurement of certain deferred tax assets with a corresponding valuation allowance.

Schedule of Gross Unrecognized Tax Benefits

A reconciliation of the beginning to the ending amount of gross unrecognized tax benefits (excluding interest and penalties) for the years ended December 31, 2015, 2014 and 2013 is as follows:

	Year Ended December 31,
	2015			2014			2013
Balance, January 1 (excluding interest and penalties of $13,004, $12,200 and $14,799, respectively)	$	68,224		$	62,905		$	55,947
Increases in gross unrecognized tax benefits relating to tax positions taken during:
Prior years		–			2,837			417
Current year		22,212			18,698			17,596
Decreases in gross unrecognized tax benefits relating to:
Tax positions taken during prior years		(621	)		(3,191	)		(385	)
Settlements with tax authorities		–			–			(5,587	)
Lapse of the applicable statute of limitations		(12,535	)		(13,025	)		(5,083	)
Balance, December 31 (excluding interest and penalties of $13,083, $13,004 and $12,200, respectively)	$	77,280		$	68,224		$	62,905

Schedule of Additional Information Relating to Unrecognized Tax Benefits

Additional information with respect to unrecognized tax benefits is as follows:

	Year Ended December 31,
	2015		2014		2013
Unrecognized tax benefits at the end of the year that, if recognized, would favorably affect the effective tax rate (includes interest and penalties of $13,083, $13,004 and $12,200, respectively)	$	74,785	$	40,353	$	36,272
Offset to deferred tax assets for unrecognized tax benefits that, if recognized, would not affect the effective tax rate	$	15,578	$	40,875	$	38,833
Interest and penalties recognized in current income tax expense (after giving effect to the reversal of interest and penalties of $3,865, $3,177 and $7,326, respectively)	$	79	$	804	$	(2,599	)