INCOME TAXES

3 Months Ended

Mar. 31, 2024

Income Tax Disclosure [Abstract]

INCOME TAXES

NOTE 12. INCOME TAXES

The effective tax rate for the three months ended March 31, 2024 included a net $2.6 million tax benefit, primarily associated with stock-based compensation and prior year tax positions, partially offset by an expense from a change in tax contingencies. Excluding these items, the effective tax rate for the three months ended March 31, 2024 of 25.0% was higher than the 21.0% U.S. federal statutory rate primarily due to state income tax and foreign income inclusions, partially offset by favorable permanent salt depletion deductions. The effective tax rate for the three months ended March 31, 2023 included a net $5.2 million tax benefit, primarily associated with stock-based compensation, a remeasurement of deferred taxes due to a decrease in our state effective tax rates, and prior year tax positions, partially offset by an expense from a net increase in the valuation allowance related to deferred tax assets in foreign jurisdictions and an expense from a change in tax contingencies. Excluding these items, the effective tax rate for the three months ended March 31, 2023 of 23.6% was higher than the 21.0% U.S. federal statutory rate primarily due to state and foreign income taxes and an increase in the valuation allowance related to losses in foreign jurisdictions, partially offset by favorable permanent salt depletion deductions.

As of March 31, 2024, we had $49.9 million of gross unrecognized tax benefits, which would have a net $49.7 million impact on the effective tax rate, if recognized. As of March 31, 2023, we had $54.8 million of gross unrecognized tax benefits, of which $53.2 million would have impacted the effective tax rate, if recognized. The amounts of unrecognized tax benefits were as follows:

	Three Months Ended March 31,
	2024		2023
Unrecognized Tax Benefits	($ in millions)
Balance at beginning of period	$	50.3	$	51.6
Increases for current year tax positions	0.4		2.8
Foreign currency translation adjustments	(0.8)		0.4
Balance at end of period	$	49.9	$	54.8

As of March 31, 2024, we believe it is reasonably possible that our total amount of unrecognized tax benefits will decrease by approximately $36.3 million over the next twelve months. The anticipated reduction primarily relates to expected settlements with tax authorities and the expiration of federal, state and foreign statutes of limitation.

We operate globally and file income tax returns in numerous jurisdictions. Our tax returns are subject to examination by various federal, state and local tax authorities. Additionally, examinations are ongoing in various states and foreign jurisdictions. We believe we have adequately provided for all tax positions; however, amounts asserted by taxing authorities could be greater than our accrued position.

For our primary tax jurisdictions, the tax years that remain subject to examination are as follows:

	Tax Years
U.S. federal income tax	2020 - 2023
U.S. state income tax	2012 - 2023
Canadian federal income tax	2017 - 2023
Brazil	2017 - 2023
Germany	2015 - 2023
China	2014 - 2023
The Netherlands	2016 - 2023