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Income Taxes (Tables)

12 Months Ended

Dec. 31, 2020

Income Before Income Taxes Attributable to Geographic Locations

Income before income taxes is attributable to the following geographic locations for the years ended December 31, (in thousands):


	2020		2019		2018
Domestic	$	18,395	$	328,806	$	298,009
Foreign	497,830		363,791		135,029
Income before income taxes	$	516,225	$	692,597	$	433,038

Components of Tax Benefit (Expenses) for Income Taxes

The tax benefit (expenses) for income taxes consisted of the following components for the years ended December 31, (in thousands):


	2020		2019		2018
Current:
Federal	$	4,552	$	(17,906)	$	7,085
State and local	1,597		(4,624)		(2,663)
Foreign	(171,092)		(135,356)		(118,175)
Subtotal	(164,943)		(157,886)		(113,753)
Deferred:
Federal	16,553		(7,459)		(27,874)
State and local	704		(1,775)		(1,165)
Foreign	1,535		(18,232)		75,113
Subtotal	18,792		(27,466)		46,074
Income tax expense	$	(146,151)	$	(185,352)	$	(67,679)

Income Tax Reconciliation

The fiscal 2020, 2019, and 2018 income tax benefit (expenses) differed from the amounts computed by applying the U.S. federal income tax rate of 21% to pre-tax income as a result of the following for the years ended December 31 (in thousands):


	2020		2019		2018
Federal tax at statutory rate	$	(109,906)	$	(145,445)	$	(90,938)
State and local tax (expense) benefit	2,071		(5,852)		(3,616)
Deferred tax assets generated in current year not benefited	(12,852)		(5,398)		(3,777)
Foreign income tax rate differential	(16,364)		(11,610)		(4,072)
Non-deductible expenses	(4,427)		(1,021)		(756)
Stock-based compensation expense	(954)		(2,105)		(2,308)
Change in valuation allowance	390		(2,870)		38,684
Foreign financing activities	(11,743)		(18,738)		(17,548)
Loss on divestments	—		(3,277)		—
Uncertain tax positions reserve	(38,014)		(35,724)		(20,440)
Tax adjustments related to REIT	50,107		63,614		32,189
Change in deferred tax adjustments	(136)		(10,574)		—
Other, net	(4,323)		(6,352)		4,903
Total income tax expense	$	(146,151)	$	(185,352)	$	(67,679)

Schedule of Deferred Tax Assets and Liabilities

The types of temporary differences that give rise to significant portions of the Company's deferred tax assets and liabilities are set out below as of December 31 (in thousands):


	2020		2019 (1)
Deferred tax assets:
Stock-based compensation expense	$	5,583	$	2,675
Unrealized losses	17,268		6,492
Lease liabilities	214,560		189,951
Loss carryforwards and tax credits	117,150		59,735
Others, net	14,976		8,500
Gross deferred tax assets	369,537		267,353
Valuation allowance	(82,344)		(57,812)
Total deferred tax assets, net	287,193		209,541
Deferred tax liabilities:
Property, plant and equipment (2)	(346,916)		(271,262)
Deferred income	(31,538)		(5,248)
Intangible assets	(132,681)		(144,404)
Total deferred tax liabilities	(511,135)		(420,914)
Net deferred tax liabilities	$	(223,942)	$	(211,373)

(1) The prior year amounts presented in the table above have been reclassified to conform with the current year presentation.

(2) Property, plant and equipment included the net deferred tax liabilities related to operating and finance lease ROU assets.

Changes in Valuation Allowance for Deferred Tax Assets

Changes in the valuation allowance for deferred tax assets for the years ended December 31, 2020, 2019 and 2018 are as follows (in thousands):


	2020		2019		2018
Beginning balance	$	57,812	$	57,003	$	84,573
Amounts from acquisitions	5,777		(2,707)		33,070
Divested balances	—		(351)		—
Amounts recognized into income	(390)		2,870		(38,684)
Current increase (decrease)	15,044		697		(13,086)
Impact of foreign currency exchange	4,101		300		(8,870)
Ending balance	$	82,344	$	57,812	$	57,003

Schedule of Net Operating Loss Carryforwards

The Company's NOL carryforwards for federal, state and foreign tax purposes which expire, if not utilized, at various intervals from 2021, are outlined below (in thousands):


Expiration Date	Federal (1)		State		Foreign (2) (3)		Total
2021	$	110,035	$	—	$	1,580	$	111,615
2022 to 2024	46,827		—		17,829		64,656
2025 to 2027	13,005		—		34,561		47,566
2028 to 2030	—		—		32,393		32,393
2031 to 2033	—		767		—		767
2034 to 2036	4,246		2,088		3,807		10,141
Thereafter	152,495		38,929		399,501		590,925
	$	326,608	$	41,784	$	489,671	$	858,063

(1)The total amount of NOL carryforwards that will not be available to offset the Company's future taxable income after dividend paid deduction due to Section 382 limitations was $165.1 million for federal.

(2)In certain jurisdictions, the net operating loss carryforwards can only be used to offset a percentage of taxable income in a given year.

(3)If certain substantial changes in the entity's ownership occur or have determined to have occurred, there may be a limitation on the amount of the carryforwards that can be utilized.

Reconciliation of Unrecognized Tax Benefits

The beginning and ending balances of the Company's unrecognized tax benefits are reconciled below for the years ended December 31 (in thousands):


	2020		2019		2018
Beginning balance	$	173,726	$	150,930	$	82,390
Gross increases related to prior year tax positions	14,732		—		33,436
Gross decreases related to prior year tax positions	—		(1,160)		—
Gross increases related to current year tax positions	29,149		31,332		48,685
Decreases resulting from expiration of statute of limitation	(6,518)		(2,112)		(1,276)
Decreases resulting from settlements	(3,330)		(5,264)		(12,305)
Ending balance	$	207,759	$	173,726	$	150,930