Income Taxes

3 Months Ended

Mar. 31, 2024

Income Tax Disclosure [Abstract]

Income Taxes

Income Taxes

The Company’s effective tax rate was 18.8% and 15.9% for the three months ended March 31, 2024 and 2023, respectively.

The effective tax rate for the three months ended March 31, 2024 was lower than the statutory rate as a result of tax preferred items including incentive compensation and foreign tax credits net of addback, partially offset by state income taxes, net of federal benefit.

The effective tax rate for the three months ended March 31, 2023 was lower than the statutory rate as a result of tax preferred items including incentive compensation, foreign tax credits net of addback, the dividends received deduction and low income housing tax credits, partially offset by state income taxes, net of federal benefit.

The higher effective tax rate for the three months ended March 31, 2024 compared to the three months ended March 31, 2023 was primarily the result of higher pretax income and a decrease in foreign tax credits net of addback, partially offset by an increase in incentive compensation compared to the prior period.

Included in the Company’s deferred income tax assets are tax benefits related to state net operating losses of $32 million, net of federal benefit, which will expire beginning December 31, 2024 and foreign net operating losses of $42 million, which do not expire.

The Company is required to establish a valuation allowance for any portion of its deferred tax assets that management believes will not be realized. Significant judgment is required in determining if a valuation allowance should be established and the amount of such allowance if required. Factors used in making this determination include estimates relating to the performance of the business. Consideration is given to, among other things in making this determination: (i) future taxable income exclusive of reversing temporary differences and carryforwards; (ii) future reversals of existing taxable temporary differences; (iii) taxable income in prior carryback years; and (iv) tax planning strategies. Based on analysis of the Company’s tax position as of March 31, 2024, management believes it is more likely than not that the Company will not realize certain state net operating losses of $31 million, state deferred tax assets of $2 million (both net of federal benefit), and foreign net operating losses of $33 million; therefore, a valuation allowance has been established. The valuation allowance was $66 million and $65 million as of March 31, 2024 and December 31, 2023, respectively.

As of March 31, 2024 and December 31, 2023, the Company had $156 million and $150 million, respectively, of gross unrecognized tax benefits. If recognized, approximately $126 million and $120 million, net of federal tax benefits, of unrecognized tax benefits as of March 31, 2024 and December 31, 2023, respectively, would affect the effective tax rate.

It is reasonably possible that the total amount of unrecognized tax benefits will change in the next 12 months. The Company estimates that the total amount of gross unrecognized tax benefits may decrease by approximately $27 million in the next 12 months primarily due to expected exam closures and state statutes of limitations expirations.

The Company recognizes interest and penalties related to unrecognized tax benefits as a component of the income tax provision. The Company recognized a net increase of $2 million and $1 million in interest and penalties for the three months ended March 31, 2024 and 2023, respectively. As of March 31, 2024 and December 31, 2023, the Company had a payable of $28 million and $26 million, respectively, related to accrued interest and penalties.

The Company or one or more of its subsidiaries files income tax returns in the U.S. federal jurisdiction and various state and foreign jurisdictions. The Internal Revenue Service (“IRS”) is currently auditing the Company’s U.S. income tax returns for 2019 and 2020. The Company’s state income tax returns are currently under examination by various jurisdictions for years ranging from 2017 through 2021.

The Company is an applicable corporation required to compute corporate alternative minimum tax (“CAMT”); however, based on current estimates the Company does not expect to be liable for the CAMT in 2024 and therefore a liability has not been recorded.

In December 2021, the Organization for Economic Co-operation and Development published the Pillar Two model rules which introduce new taxing mechanisms aimed at ensuring multinational enterprises pay a minimum level of tax on profits from each jurisdiction in which they operate. Various jurisdictions that the Company operates in have enacted or substantively enacted legislation that became effective beginning January 1, 2024. The Company intends to rely on Pillar Two transitional safe harbors where available and, based on its current estimate, has not recorded any Pillar Two tax liabilities. The Company continues to monitor the adoption and implementation of these rules and evaluate the potential impact on its consolidated financial statements.