Income Taxes

12 Months Ended

Dec. 31, 2022

Income Tax Disclosure [Abstract]

Income Taxes

Income Taxes

The Company is subject to U.S. federal, state, and foreign income taxes. Components of income before income taxes consist of the following:

	Year Ended December 31,
(In millions)	2022		2021		2020
United States	$	839.9	$	5,944.7	$	2,442.3
Foreign	4,018.9		3,381.1		1,368.1
	$	4,858.8	$	9,325.8	$	3,810.4

Components of income tax expense consist of the following:

	Year Ended December 31,
(In millions)	2022		2021		2020
Current:
Federal	$	968.5	$	1,429.8	$	199.0
State	7.4		6.2		1.2
Foreign	290.9		(38.4)		21.4
Total current tax expense	1,266.8		1,397.6		221.6
Deferred:
Federal	(797.7)		(423.2)		109.0
State	(2.7)		(0.6)		(2.0)
Foreign	54.0		276.7		(31.4)
Total deferred tax (benefit) expense	(746.4)		(147.1)		75.6
	$	520.4	$	1,250.5	$	297.2

A reconciliation of the U.S. statutory income tax rate to the Company's effective income tax rate is as follows:

	Year Ended December 31,
	2022		2021		2020
U.S. federal statutory tax rate	21.0	%	21.0	%	21.0	%
Taxation of non-U.S. operations	(5.5)		(2.8)		(1.8)
Stock-based compensation	(2.9)		(2.4)		(7.6)
Income tax credits	(2.0)		(1.0)		(2.8)
Foreign-derived intangible income deduction	(1.0)		(1.4)		—
Sale of non-inventory related assets between foreign subsidiaries	—		—		(0.8)
Other permanent differences	1.1		—		(0.2)
Effective income tax rate	10.7	%	13.4	%	7.8	%

Deferred income taxes reflect the net tax effects of temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for income tax purposes. Significant components of the Company's deferred tax assets and liabilities are as follows:

	As of December 31,
(In millions)	2022		2021
Deferred tax assets:
Capitalized research and development expenses	$	845.3	$	—
Deferred compensation	416.2		406.6
Accrued expenses	235.6		262.1
Fixed assets and intangible assets	227.6		257.5
Tax attribute carryforwards	41.3		6.1
Other	15.9		10.8
Deferred revenue	—		57.3
Total deferred tax assets	1,781.9		1,000.4
Deferred tax liabilities:
Unrealized gains on investments	(58.2)		(123.5)
Net deferred tax assets	$	1,723.7	$	876.9

The Company's federal income tax returns for 2017 through 2021 remain open to examination by the IRS. The Company's 2017 and 2018 federal income tax returns are currently under audit by the IRS. In general, the Company's state income tax returns from 2018 to 2021 remain open to examination. The Company's income tax returns outside of the United States remain open to examination from 2018 to 2021. The United States and many states generally have statutes of limitation ranging from 3 to 5 years; however, those statutes could be extended due to the Company's tax credit carryforward position. In general, tax authorities have the ability to review income tax returns in which the statute of limitation has previously expired to adjust the tax credits generated in those years.

The amount of net unrecognized tax benefits that, if settled, would impact the effective tax rate is $373.7 million, $321.1 million, and $267.0 million as of December 31, 2022, 2021, and 2020, respectively. The following table reconciles the beginning and ending amounts of unrecognized tax benefits.

(In millions)	2022		2021		2020
Balance as of January 1	$	410.9	$	267.0	$	210.8
Gross increases related to current year tax positions	136.9		182.3		76.6
Gross (decreases) increases related to prior year tax positions	(5.0)		2.9		7.2
Gross decreases due to settlements and lapse of statutes of limitations	—		(41.3)		(27.6)
Balance as of December 31	$	542.8	$	410.9	$	267.0

In 2022, 2021, and 2020, the increases in unrecognized tax benefits primarily related to the Company's calculation of certain tax credits and other items related to the Company's international operations. The decrease in unrecognized tax benefits in 2021 was related to the closing of audits for the Company's federal income tax returns for 2015 and 2016. Interest expense related to unrecognized tax benefits was not material in 2022, 2021, and 2020. The Company does not believe that it is reasonably possible that the resolution of tax exposures within the next twelve months would have a material impact on the consolidated financial statements as of December 31, 2022.

In August 2022, the Inflation Reduction Act of 2022 ("IRA") was signed into law in the United States. The IRA created a new corporate alternative minimum tax of 15% on adjusted financial statement income and an excise tax of 1% of the value of certain stock repurchases. The provisions of the IRA will be effective for periods beginning after December 31, 2022. The enactment of the IRA did not result in any material adjustments to the Company's income tax provisions or net deferred tax assets as of December 31, 2022.