Income Taxes

12 Months Ended

Dec. 31, 2024

Income Tax Disclosure [Abstract]

Income Taxes

NOTE 13. INCOME TAXES

Components of Earnings Before Income Taxes

The following table summarizes the components of earnings before income taxes for the years ended December 31 (in thousands):

	2024		2023		2022
Domestic	$	3,595,449	$	2,891,644	$	2,423,809
International		519,429		572,539		1,267,001
Earnings before income taxes	$	4,114,878	$	3,464,183	$	3,690,810

Summary of Current and Deferred Income Taxes

The following table summarizes the components of the provision for income taxes for the years ended December 31 (in thousands):

	2024			2023			2022
Current income tax expense (benefit):
U.S. federal	$	(17,082	)	$	(953	)	$	(6,645	)
International		152,891			175,121			112,489
State and local		9,973			19,162			16,930
Total current income tax expense		145,782			193,330			122,774
Deferred income tax expense:
U.S. federal		18,222			12,936			3,359
International		2,939			4,772			9,279
Total deferred income tax expense		21,161			17,708			12,638
Total income tax expense	$	166,943		$	211,038		$	135,412

Current Income Taxes

We recognize current income tax expense for the federal and state income taxes incurred by our TRSs and taxes incurred in certain states and foreign jurisdictions. Current income tax expense fluctuates from period to period based primarily on the timing of our taxable income. Taxable income incurred over the last three years was principally due to the following: (i) the contribution of real estate properties to our unconsolidated co-investment ventures and sales to third parties; (ii) recurring and transactional strategic capital fees earned; (iii) taxable earnings from unconsolidated co-investment ventures; and (iv) adjustments to acquired tax liabilities.

During the years ended December 31, 2024, 2023 and 2022, cash paid for income taxes, net of refunds, was $129.9 million, $149.1 million and $130.0 million, respectively.

Deferred Income Taxes

The deferred income tax expense recognized in 2024, 2023 and 2022 was principally due to changes in temporary differences and utilization of NOLs.

The following table summarizes the deferred income tax assets and liabilities at December 31 (in thousands):

	2024			2023
Gross deferred income tax assets:
NOL carryforwards	$	263,597		$	246,768
Basis difference – real estate properties		43,226			48,460
Basis difference – equity investments		18,434			18,051
Section 163(j) interest limitation		2,105			1,689
Capital loss carryforward		6,096			7,161
Other – temporary differences		29,908			9,142
Total gross deferred income tax assets		363,366			331,271
Valuation allowance		(312,348	)		(305,063	)
Gross deferred income tax assets, net of valuation allowance		51,018			26,208
Gross deferred income tax liabilities:
Basis difference – real estate properties		128,803			98,529
Basis difference – equity investments		57,763			43,457
Other – temporary differences		2,321			1,673
Total gross deferred income tax liabilities		188,887			143,659
Net deferred income tax liabilities	$	137,869		$	117,451

At December 31, 2024, we had NOL carryforwards as follows (in thousands):

	U.S.		Europe		Mexico		Japan		Other
Gross NOL carryforward	$	81,637	$	559,070	$	240,939	$	54,200	$	34,157
Tax-effected NOL carryforward		21,093		150,434		75,429		8,036		8,605
Valuation allowance		21,093		140,453		75,429		8,036		8,605
Net deferred tax asset – NOL carryforward	$	-	$	9,981	$	-	$	-	$	-
Expiration periods	2025 – 2044		2025 – indefinite		2025 – 2034		2025 – 2034		2025 – indefinite

The deferred tax asset valuation allowance at December 31, 2024, was adequate to reduce the total deferred tax asset to an amount that we estimate will more likely than not be realized.

Liability for Uncertain Tax Positions

During the years ended December 31, 2024, 2023 and 2022, we believe that we had complied with the REIT requirements of the IRC. The statute of limitations for our global tax returns is generally three to five years. As such, our tax returns that remain subject to examination would be primarily from 2019 and thereafter. During the year ended December 31, 2024, we recognized a $20.7 million liability for uncertain tax positions related to proposed settlements. Liabilities or any related settlements for uncertain tax positions for the years ended December 31, 2023 and 2022 were not material to our Consolidated Financial Statements.