Income Taxes (Tables)

12 Months Ended

Dec. 31, 2024

The provision for income taxes consisted of the following (in thousands):


	Year Ended December 31,
	2024		2023		2022
Current:
U.S. federal	$	19,459	$	19,297	$	12,949
U.S. state and local	5,061		5,033		6,147
Foreign	95,149		54,787		34,506
UBT	—		373		(390)
	119,669		79,490		53,212
Deferred:
U.S. federal	(58,127)		(41,491)		(17,083)
U.S. state and local	(9,568)		(14,989)		(1,596)
Foreign	(2,059)		(5,914)		3,971
UBT	—		1,838		80
	(69,754)		(60,556)		(14,628)
Provision for income taxes	$	49,915	$	18,934	$	38,584

Schedule of Actual Income Tax Expense and Amount Calculated Utilizing U.S. Federal Statutory Rates

Differences between the Company’s actual income tax expense and the amount calculated utilizing the U.S. federal statutory rates were as follows (in thousands):


	Year Ended December 31,
	2024		2023		2022
Tax expense at federal statutory rate	$	36,360	$	12,207	$	20,584
Non-controlling interest	1,295		1,982		2,366
Incremental impact of foreign taxes compared to federal tax rate	5,847		3,838		8,122
Other permanent differences	(2,153)		3,054		(10,105)
U.S. state and local taxes, net of U.S. federal benefit	(4,408)		(4,778)		(876)
New York City UBT	—		—		(1,071)
Other rate changes	1,503		(862)		153
Impact of Corporate Conversion	—		(12,446)		—
Uncertain tax positions	304		(797)		3,496
U.S. tax on foreign earnings, net of tax credits	(4,413)		12,388		4,808
Prior year adjustments	5,811		4,078		4,189
Valuation allowance	(2,402)		(4,190)		(4,670)
Meals and Entertainment	7,450		6,182		12,681
Impact of RSU Windfall	(4,433)		(1,700)		(289)
AFS MTM — U.S. GAAP Adjustment1	9,154		—		—
Other	—		(22)		(804)
Provision for income taxes	$	49,915	$	18,934	$	38,584

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1Available for sale securities mark-to-market — U.S. GAAP Adjustment

Schedule of Deferred Tax Asset and Liability

Significant components of the Company’s deferred tax asset and liability consisted of the following (in thousands):


	Year Ended December 31,
	2024		2023
Deferred tax asset
Basis difference of investments	$	10,403	$	23,522
Deferred compensation	114,680		90,270
Excess interest expense	90,404		55,040
Other deferred and accrued expenses	10,659		17,625
Depreciation and amortization	790		—
Net operating loss and credit carry-forwards	58,084		43,426
Total deferred tax asset1	285,020		229,883
Valuation allowance	(24,422)		(27,813)
Deferred tax asset, net of valuation allowance	260,598		202,070
Deferred tax liability
Depreciation and amortization	—		10,618
Total deferred tax liability1	—		10,618
Net deferred tax asset	$	260,598	$	191,452

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1Before netting within tax jurisdictions.

Schedule of Gross Unrecognized Tax Benefits

A reconciliation of the beginning to the ending amounts of gross unrecognized tax benefits for the years ended December 31, 2024 and 2023 is as follows (in thousands):


Balance, December 31, 2022	$	7,553
Increases for prior year tax positions	—
Decreases for prior year tax positions	(884)
Increases for current year tax positions	—
Decreases related to settlements with taxing authorities	—
Decreases related to a lapse of applicable statute of limitations	—
Balance, December 31, 2023	$	6,669
Increases for prior year tax positions	—
Decreases for prior year tax positions	—
Increases for current year tax positions	—
Decreases related to settlements with taxing authorities	—
Decreases related to a lapse of applicable statute of limitations	(2,025)
Balance, December 31, 2024	$	4,644