Income Taxes (Tables)

12 Months Ended

Dec. 31, 2021

Components of deferred tax assets and liabilities

The components of the Company’s deferred tax assets and liabilities were as follows:


	December 31,
(in millions)	2021		2020
Deferred tax assets:
Stock-based compensation expense	$	10.6	$	18.2
Accrued expenses	86.2		43.3
Financing and operating leasing obligations	2,351.3		2,336.9
Unrecognized tax benefits	8.9		7.9

Net operating losses, interest limitation and tax credit carryforwards	115.7		153.9
Gross deferred tax assets	2,572.7		2,560.2
Less: Valuation allowance	(124.3)		(101.0)
Net deferred tax assets	2,448.4		2,459.2
Deferred tax liabilities:
Property and equipment, not subject to the Master Leases	(65.6)		(51.1)
Property and equipment, subject to the Master Leases	(992.9)		(1,051.2)
Investments in and advances to unconsolidated affiliates	(6.8)		(27.9)
Discount on convertible notes	(18.1)		(20.9)
Undistributed foreign earnings	—		(0.4)
Intangible assets	(284.8)		(183.4)
Lease right of use assets	(1,269.3)		(1,250.6)
Net deferred tax liabilities	(2,637.5)		(2,585.5)
Long-term deferred tax liabilities, net	$	(189.1)	$	(126.3)

Components of income before income tax expense

The domestic and foreign components of income (loss) before income taxes for the years ended December 31, 2021, 2020 and 2019 were as follows:


	For the year ended December 31,
(in millions)	2021		2020		2019
Domestic	$	606.0	$	(834.0)	$	85.5
Foreign	(66.9)		(0.2)		0.6
Total	$	539.1	$	(834.2)	$	86.1

Schedule of provision for income taxes

The components of income tax benefit (expense) for the years ended December 31, 2021, 2020 and 2019 were as follows:


	For the year ended December 31,
(in millions)	2021		2020		2019
Current tax benefit (expense)
Federal	$	(100.0)	$	47.0	$	(12.5)
State	(23.1)		0.2		(9.2)
Foreign	—		(0.4)		(0.2)
Total current	(123.1)		46.8		(21.9)
Deferred tax benefit (expense)
Federal	(11.9)		103.6		(16.7)
State	13.3		14.7		(4.4)
Foreign	3.1		—		—
Total deferred	4.5		118.3		(21.1)
Total income tax benefit (expense)	$	(118.6)	$	165.1	$	(43.0)

Reconciliation of the statutory federal income tax rate to the actual effective income tax rate

The following table reconciles the statutory federal income tax rate to the actual effective income tax rate, and related amounts of income tax benefit (expense), for the years ended December 31, 2021, 2020 and 2019:


	For the year ended December 31,
	2021				2020				2019
(in millions, except tax rates)	Percent		Amount		Percent		Amount		Percent		Amount
Percent and amount of pretax income
Federal statutory rate	21.0	%	$	(113.2)	21.0	%	$	175.2	21.0	%	$	(18.1)
State and local income taxes, net of federal benefits	1.4		(7.7)		1.4		12.1		9.9		(8.5)
Nondeductible expenses	2.5		(13.3)		(0.3)		(2.6)		4.0		(3.5)
Goodwill impairment losses	—		—		(2.3)		(19.0)		14.4		(12.4)
Compensation	(1.2)		6.5		2.5		20.5		0.3		(0.3)
Foreign	(0.2)		0.9		—		(0.4)		0.1		(0.1)
Federal valuation allowance	1.1		(5.9)		(3.9)		(32.7)		—		—
Tax credits	(1.1)		5.8		1.2		10.0		—		—
Equity investment write-off	(2.1)		11.3		—		—		—		—
Other	0.6		(3.0)		0.2		2.0		0.2		(0.1)
Total effective tax rate and income tax benefit (expense)	22.0	%	$	(118.6)	19.8	%	$	165.1	49.9	%	$	(43.0)

Reconciliation of unrecognized tax benefits

A reconciliation of the beginning and ending amounts of unrecognized tax benefits is as follows:


(in millions)	Unrecognized tax benefits
Unrecognized tax benefits as of January 1, 2019	$	29.7
Additions based on prior year positions	6.5
Decreases due to settlements and/or reduction in reserves	(0.2)
Unrecognized tax benefits as of December 31, 2019	36.0
Additions based on prior year positions	1.2
Decreases due to settlements and/or reduction in reserves	(0.9)
Unrecognized tax benefits as of December 31, 2020	36.3
Additions based on prior year positions	3.8
Decreases due to settlements and/or reduction in reserves	(0.1)
Unrecognized tax benefits as of December 31, 2021	$	40.0