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Income Taxes
12 Months Ended
Nov. 30, 2022
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The provision for income tax expense consists of the following components (in thousands):
Year Ended November 30,
202220212020
Current:
U.S. Federal$198,507 $322,551 $90,350 
U.S. state and local67,236 70,370 68,261 
Foreign78,505 86,918 75,395 
Total current344,248 479,839 234,006 
Deferred:
U.S. Federal(61,303)72,753 52,765 
U.S. state and local(17,010)19,502 (1,288)
Foreign7,917 4,635 13,190 
Total deferred(70,396)96,890 64,667 
Total income tax expense$273,852 $576,729 $298,673 
The following table presents the U.S. and non-U.S. components of earnings before income tax expense (in thousands):
Year Ended November 30,
202220212020
U.S.
$801,047 $1,970,625 $813,305 
Non-U.S. (1)
254,515 283,480 253,778 
Earnings before income tax expense$1,055,562 $2,254,105 $1,067,083 
(1)For purposes of this table, non-U.S. income is defined as income generated from operations located outside the U.S.
Income tax expense differed from the amounts computed by applying the U.S. Federal statutory income tax rate of 21.0% to earnings before income taxes as a result of the following (dollars in thousands):
Year Ended November 30,
202220212020
AmountPercentAmountPercentAmountPercent
Computed expected federal income taxes$221,668 21.0 %$473,362 21.0 %$224,087 21.0 %
Increase (decrease) in income taxes resulting from:
State and local income taxes, net of Federal income tax benefit47,364 4.5 96,884 4.3 45,457 4.3 
International operations (including foreign rate differential)18,711 1.8 18,073 0.8 13,155 1.2 
Non-deductible executive compensation12,596 1.2 20,359 0.9 12,814 1.2 
Foreign tax credits, net(20,368)(1.9)(13,963)(0.6)(8,654)(0.8)
Employee share-based awards(37,988)(3.6)893 — 209 — 
Regulatory Settlement20,184 1.9 — — — — 
Change in unrecognized tax benefits related to prior years (16,915)(1.7)(27,374)(1.2)(4,522)(0.5)
Interest on unrecognized tax benefits13,902 1.3 8,651 0.4 15,600 1.5 
Other, net14,698 1.4 (156)— 527 0.1 
Total income tax expense$273,852 25.9 %$576,729 25.6 %$298,673 28.0 %
The following table presents a reconciliation of gross unrecognized tax benefits (in thousands):
Year Ended November 30,
202220212020
Balance at beginning of period$339,036 $314,347 $260,138 
Increases based on tax positions related to the current period30,690 50,079 41,114 
Increases based on tax positions related to prior periods5,902 3,490 22,328 
Decreases based on tax positions related to prior periods(25,673)(24,180)(8,966)
Decreases related to settlements with taxing authorities— (4,700)(267)
Balance at end of period$349,955 $339,036 $314,347 
The total amount of unrecognized benefits that, if recognized, would favorably affect the effective tax rate was $276.5 million and $267.8 million (net of Federal benefit) at November 30, 2022 and 2021, respectively.
We recognize interest accrued related to unrecognized tax benefits and penalties, if any, as components of Income tax expense. Net interest expense related to unrecognized tax benefits was $18.6 million, $10.8 million and $19.9 million for the years ended November 30, 2022, 2021 and 2020, respectively. At November 30, 2022, 2021 and 2020, we had interest accrued of approximately $116.5 million, $97.9 million and $87.1 million, respectively, included in Accrued expenses and other liabilities in our Consolidated Statements of Financial Condition. No material penalties were accrued for the years ended November 30, 2022, 2021 and 2020.
The cumulative tax effects of temporary differences that give rise to significant portions of the deferred tax assets and liabilities are presented below (in thousands):
November 30,
20222021
Deferred tax assets:
Compensation and benefits$250,096 $187,818 
Operating lease liabilities133,250 135,862 
Long-term debt47,535 65,037 
Accrued expenses and other166,564 178,451 
Investments in associated companies11,931 1,135 
Sub-total609,376 568,303 
Valuation allowance(6,266)(11,922)
Total deferred tax assets603,110 556,381 
Deferred tax liabilities:
Operating lease right-of-use assets118,567 126,150 
Amortization of intangibles62,670 62,123 
Other34,011 40,561 
Total deferred tax liabilities215,248 228,834 
Net deferred tax asset, included in Other assets$387,862 $327,547 
The valuation allowance represents the portion of our deferred tax assets for which it is more likely than not that the benefit of such items will not be realized. We believe that the realization of the net deferred tax asset of $387.9 million at November 30, 2022 is more likely than not based on expectations of future taxable income in the jurisdictions in which we operate.
At November 30, 2022, we had gross net operating loss carryforwards of $10.2 million, primarily related to various state and local jurisdictions. This balance has been partially offset by a valuation allowance of $4.5 million. The remaining valuation allowance is attributable to deferred tax assets related to compensation and benefits in the U.K.
We are currently under examination by a number of taxing jurisdictions. Though we do not expect that resolution of these examinations will have a material effect on our consolidated financial position, they may have a material impact on our consolidated results of operations for the period in which resolution occurs. It is reasonably possible that, within the next twelve months, statutes of limitation will expire which would have the effect of reducing the balance of unrecognized tax benefits by $26.3 million.
The table below summarizes the earliest tax years that remain subject to examination in the major tax jurisdictions in which we operate:
JurisdictionTax Year
United States2019
New York State2001
New York City2006
United Kingdom2021
Germany2017
Hong Kong2016
India2010
We will recognize any U.S. income tax expense we may incur on global intangible low-taxed income as income tax expense in the period in which the tax is incurred.
On August 16, 2022, the Inflation Reduction Act of 2022 was signed into law. The Inflation Reduction Act of 2022 includes a 15% corporate alternative minimum tax (“AMT”) and a one percent excise tax on net stock repurchases. The corporate AMT applies to corporations with average annual profits over $1 billion and is calculated on their financial statement income, with certain adjustments, and will apply to our tax year beginning December 1, 2023. The one percent excise tax on net stock repurchases is effective January 1, 2023. We do not expect that these changes will have a significant effect on our future effective tax rate, but we will continue to evaluate the nature and monitor the extent of the potential impacts.