Income Taxes

12 Months Ended

Dec. 31, 2022

Income Tax Disclosure [Abstract]

Income Taxes

Income Taxes

Income from continuing operations before income taxes by geographic region was as follows:

	Year Ended December 31,
	2022		2021		2020
U.S.	$	1,474.5	$	1,242.6	$	512.4
Non-U.S.	384.7		365.1		195.2
Income from continuing operations before income taxes	$	1,859.2	$	1,607.7	$	707.6

Income taxes relating to income from continuing operations consisted of the following:

	Year Ended December 31,
	2022		2021		2020
Current:
Federal	$	200.6	$	115.7	$	(78.1)
State and local	71.6		48.1		7.3
Non-U.S.	76.6		67.7		39.2
Total current	$	348.8	$	231.5	$	(31.6)
Deferred:
Federal	98.8		129.9		165.4
State and local	17.1		33.9		22.5
Non-U.S.	8.3		21.0		6.4
Total deferred	$	124.2	$	184.8	$	194.3
Income taxes	$	473.0	$	416.3	$	162.7

Income taxes relating to income from continuing operations varied from the U.S. federal statutory income tax rate due to the following:

	Year Ended December 31,
	2022		2021		2020
Income taxes at federal statutory rate	$	390.4	$	337.6	$	148.6
State and local income taxes, net of federal taxes	67.3		64.6		21.9
Non-U.S. income taxed at other rates	4.1		11.9		4.6
Rate differential from NOL carryback	—		—		(21.6)
Foreign tax credit revaluation	—		—		12.3
Other	11.2		2.2		(3.1)
Income taxes	$	473.0	$	416.3	$	162.7

The components of deferred tax assets and liabilities as of December 31, 2022 and 2021 were as follows:

	December 31,
	2022		2021
Deferred Tax Assets
Accrued liabilities	$	68.9	$	68.7
Net operating loss and credit carryforwards	50.5		60.7
Leasing liabilities	628.7		605.4
Other	36.6		31.0
Total deferred tax assets	784.7		765.8
Valuation allowance	(62.8)		(67.0)
Net deferred tax assets	$	721.9	$	698.8
Deferred Tax Liabilities
Depreciation and amortization	(314.1)		(283.8)
Partnership investments	(890.4)		(861.4)
Leasing assets	(628.7)		(605.4)
Other	(9.7)		(8.6)
Total deferred tax liabilities	(1,842.9)		(1,759.2)
Net deferred tax liabilities	$	(1,121.0)	$	(1,060.4)

We are not permanently reinvested in a portion of our previously taxed unremitted foreign earnings, which may be distributed in the future. At December 31, 2022, we have accrued the appropriate amount of U.S. state income taxes and foreign withholding taxes for the unremitted foreign earnings that are not permanently reinvested. We have not provided any U.S. taxes on a total temporary difference of $198.8 million related to the excess of financial reporting basis over tax basis in our non-U.S. subsidiaries as it is our position that we are permanently reinvested for this basis difference.

At December 31, 2022, we have $123.5 million of state net operating loss carryforwards in the U.S. that expire at various dates beginning in 2023 through 2040, a U.S. foreign tax credit carryforward of $32.0 million that will expire beginning in 2027, U.K. capital loss carryforwards of $5.0 million that will not expire, Germany net operating loss carryforwards of $32.1 million that will not expire, Italy net operating loss carryforwards of $0.1 million that will not expire, and Japan net operating loss carryforwards of $0.4 million that will expire in 2030. The Company used $117.5 million of state net operating loss carryforwards in the U.S. in 2022.

A valuation allowance of $0.7 million has been recorded against the state net operating loss carryforwards in the U.S. and a valuation allowance of $32.0 million has been recorded against the U.S. foreign tax credit carryforward as of December 31, 2022. A valuation allowance of $9.9 million has been recorded against German net operating losses and other deferred tax assets. A valuation allowance of $19.6 million has been recorded against U.K. deferred tax assets related to buildings as of December 31, 2022. A valuation allowance of $0.5 million has been recorded against Japan net operating losses and other deferred tax assets.

Generally accepted accounting principles relating to uncertain income tax positions prescribe a minimum recognition threshold a tax position is required to meet before being recognized and provides guidance on the derecognition,

measurement, classification, and disclosure relating to income taxes. The movement in uncertain tax positions for the years ended December 31, 2022, 2021, and 2020 were as follows:

	Year Ended December 31,
	2022		2021		2020
Uncertain tax positions — January 1	$	0.5	$	0.1	$	0.1
Gross increase — tax position in prior periods	—		0.4		—
Gross decrease — tax position in prior periods	—		—		—
Gross increase — current period tax position	—		—		—
Settlements	—		—		—
Lapse in statute of limitations	—		—		—
Foreign exchange	—		—		—
Uncertain tax positions — December 31	$	0.5	$	0.5	$	0.1

We have elected to include interest and penalties in our income tax expense. The total interest and penalties included within uncertain tax positions at December 31, 2022, were $0. We do not expect a significant change to the amount of uncertain tax positions within the next twelve months. Our U.S. federal returns remain open to examination for 2017, 2019, 2020, and 2021 and various U.S. state jurisdictions are open for periods ranging from 2017 through 2021. The portion of the total amount of uncertain tax positions as of December 31, 2022, that would, if recognized, impact the effective tax rate was $0.5 million.

We have classified our tax reserves as a long-term obligation on the basis that management does not expect to make payments relating to those reserves within the next twelve months.