Income Taxes

12 Months Ended

Dec. 31, 2024

Income Tax Disclosure [Abstract]

Income Taxes

Income Taxes

Income before income taxes by geographic region was as follows:

	Year Ended December 31,
	2024		2023		2022
U.S.	$	976.4	$	1,119.9	$	1,474.5
Non-U.S.	263.5		299.6		384.7
Income before income taxes	$	1,239.9	$	1,419.5	$	1,859.2

Income taxes consisted of the following:

	Year Ended December 31,
	2024		2023		2022
Current:
Federal	$	215.4	$	131.0	$	200.6
State and local	43.1		53.4		71.6
Non-U.S.	71.0		74.7		76.6
Total current	$	329.5	$	259.1	$	348.8
Deferred:
Federal	(19.7)		85.5		98.8
State and local	4.1		10.0		17.1
Non-U.S.	2.6		6.3		8.3
Total deferred	$	(13.0)	$	101.8	$	124.2
Income taxes	$	316.5	$	360.9	$	473.0

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

	Year Ended December 31,
	2024		2023		2022
Income taxes at federal statutory rate	$	260.3	$	298.1	$	390.4
State and local income taxes, net of federal taxes	40.5		47.7		67.3
Non-U.S. income taxed at other rates	18.3		18.2		4.1
Other	(2.6)		(3.1)		11.2
Income taxes	$	316.5	$	360.9	$	473.0

The components of deferred tax assets and liabilities as of December 31, 2024 and 2023 were as follows:

	December 31,
	2024		2023
Deferred Tax Assets
Accrued liabilities	$	79.9	$	77.3
Net operating loss and credit carryforwards	47.0		49.3
Leasing liabilities	641.7		624.8
Other	44.5		36.6
Total deferred tax assets	813.1		788.0
Valuation allowance	(59.2)		(58.2)
Net deferred tax assets	$	753.9	$	729.8
Deferred Tax Liabilities
Depreciation and amortization	(402.2)		(354.2)
Partnership investments	(930.0)		(972.1)
Leasing assets	(641.7)		(624.8)
Other	(11.0)		(10.4)
Total deferred tax liabilities	(1,984.9)		(1,961.5)
Net deferred tax liabilities	$	(1,231.0)	$	(1,231.7)

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, 2024, 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 $436.1 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, 2024, we have $93.3 million of state net operating loss carryforwards in the U.S. that expire at various dates beginning in 2025 through 2045, a U.S. foreign tax credit carryforward of $32.0 million that will expire beginning in 2027, U.K. capital loss carryforwards of $6.3 million that will not expire, Germany net operating loss carryforwards of $23.9 million that will not expire, Italy net operating loss carryforwards of $0.1 million that will not expire, and New Zealand net operating loss carryforwards of $0.3 million that will not expire. The Company used $16.2 million of state net operating loss carryforwards in the U.S. in 2024.

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, 2024. A valuation allowance of $2.3 million has been recorded against German net operating losses and other deferred tax assets. A valuation allowance of $24.2 million has been recorded against U.K. deferred tax assets related to buildings as of December 31, 2024.

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

We have elected to include interest and penalties in our income tax expense. There were no amounts of interest or penalties to be included within uncertain tax positions at December 31, 2024. 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 2021, 2022, and 2023 and various U.S. state jurisdictions are open for periods ranging from 2019 through 2023. The portion of the total amount of uncertain tax positions that would, if recognized, impact the effective tax rate was $0.5 million as of December 31, 2024, 2023, and 2022, respectively.