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Income Taxes
 12 Months Ended
Dec. 31, 2025
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
Income before income taxes by geographic region was as follows:
Year Ended December 31,
202520242023
U.S.$998.8 $1,026.4 $1,175.5 
Non-U.S.264.9 263.5 299.6 
Income before income taxes$1,263.7 $1,289.9 $1,475.1 
Income taxes consisted of the following:
Year Ended December 31,
202520242023
Current:
Federal$143.9 $215.4 $131.0 
State and local42.7 43.1 53.4 
Non-U.S.73.0 71.0 74.7 
Total current$259.6 $329.5 $259.1 
Deferred:
Federal44.6 (19.7)85.5 
State and local17.0 4.1 10.0 
Non-U.S.4.6 2.6 6.3 
Total deferred$66.2 $(13.0)$101.8 
Income taxes$325.8 $316.5 $360.9 
Income taxes varied from the U.S. federal statutory income tax rate due to the following:
Year Ended December 31,
202520242023
AmountPercentAmountPercentAmountPercent
Income taxes at federal statutory rate$265.4 21.0 %$270.8 21.0 %$309.8 21.0 %
State and local income taxes, net of federal taxes (1)
$48.4 3.8 %$40.5 3.1 %$47.7 3.2 %
Foreign Tax Effects
Non-U.S. income taxed at other rates$22.0 1.7 %$18.3 1.4 %$18.2 1.2 %
Other adjustments$(10.0)(0.8)%$(13.1)(1.0)%$(14.8)(1.0)%
Effective tax rate$325.8 25.8 %$316.5 24.5 %$360.9 24.5 %
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(1)State taxes in California, New Jersey, Georgia, Arizona, and Pennsylvania made up the majority (greater than 50 percent) of the tax effect in this category.
The components of deferred tax assets and liabilities as of December 31, 2025 and 2024 were as follows:
December 31,
20252024
Deferred Tax Assets
Accrued liabilities$84.0 $79.9 
Net operating loss and credit carryforwards46.2 47.0 
Leasing liabilities665.7 641.7 
Other46.4 44.5 
Total deferred tax assets842.3 813.1 
Valuation allowance(61.9)(59.2)
Net deferred tax assets$780.4 $753.9 
Deferred Tax Liabilities
Depreciation and amortization(329.7)(402.2)
Partnership investments(979.1)(930.0)
Leasing assets(662.4)(641.7)
Other(9.6)(11.0)
Total deferred tax liabilities(1,980.8)(1,984.9)
Net deferred tax liabilities$(1,200.4)$(1,231.0)
Cash paid for income taxes (net of refunds) consisted of the following:
Year Ended December 31,
202520242023
Federal$153.2 $206.0 $158.0 
State and local43.3 39.8 55.5 
Non-U.S.
United Kingdom27.4 28.9 36.2 
Australia17.8 17.9 10.7 
Other29.8 24.8 27.7 
Total cash paid for income taxes$271.5 $317.4 $288.1 
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, 2025, 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 any temporary difference 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 that basis difference. Determination of the deferred tax liability, if any, associated with this permanently reinvested basis difference is not practicable.
At December 31, 2025, we have $90.3 million of state net operating loss carryforwards in the U.S. that expire at various dates beginning in 2026 through 2047, a U.S. foreign tax credit carryforward of $32.0 million that will expire beginning in 2027, U.K. capital loss carryforwards of $5.9 million that will not expire, Germany net operating loss carryforwards of $19.2 million that will not expire, Italy net operating loss carryforwards of $0.1 million that will not expire, New Zealand net operating loss carryforwards of $2.8 million that will not expire, and Japan net operating loss carryforwards of $1.3 million that will expire in 2035. The Company used $6.4 million of state net operating loss carryforwards in the U.S. in 2025.
A valuation allowance of $0.6 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, 2025. A valuation allowance of $0.3 million has been recorded against German net operating losses and other deferred tax assets. A valuation allowance of $29.0 million has been recorded against U.K. deferred tax assets related to buildings as of December 31, 2025.
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, 2025. 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 2022, 2023, and 2024 and various U.S. state jurisdictions are open for periods ranging from 2020 through 2024. The portion of the total amount of uncertain tax positions that would, if recognized, impact the effective tax rate was $0.0 million, $0.5 million, and $0.5 million as of December 31, 2025, 2024, and 2023, respectively.
On November 19, 2025, we acquired PMG from a commonly controlled affiliate, which was accounted for as a transaction between entities under common control. Historically, PMG was treated as a pass-through partnership for income tax purposes and therefore did not record income tax expense in its stand-alone financial statements. Because we have retrospectively recast prior periods to include PMG as if it had always been part of our consolidated reporting, those historical periods do not reflect federal and state income taxes that would have been incurred had PMG been included in our taxable consolidated group. Beginning on the acquisition date, the results of PMG are included in our consolidated federal and state income tax filings and therefore subject to income tax.