Income Taxes (Tables)

12 Months Ended

Dec. 31, 2022

Income Tax Disclosure [Abstract]

Schedule of 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):

	2022		2021		2020
Domestic	$	334,486	$	137,492	$	18,395
Foreign	494,883		471,460		497,830
Income before income taxes	$	829,369	$	608,952	$	516,225

Schedule of 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):

	2022		2021		2020
Current:
Federal	$	1,679	$	7,753	$	4,552
State and local	(892)		(156)		1,597
Foreign	(83,210)		(76,450)		(171,092)
Subtotal	(82,423)		(68,853)		(164,943)
Deferred:
Federal	(16,284)		11,060		16,553
State and local	(5,024)		(1,411)		704
Foreign	(21,061)		(50,020)		1,535
Subtotal	(42,369)		(40,371)		18,792
Income tax expense	$	(124,792)	$	(109,224)	$	(146,151)

Schedule of Income Tax Reconciliation

The fiscal 2022, 2021, and 2020 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):

	2022		2021		2020
Federal tax at statutory rate	$	(174,168)	$	(127,880)	$	(109,906)
State and local tax (expense) benefit	(5,916)		(1,513)		2,071
Deferred tax assets generated in current year not benefited	(39,196)		(19,703)		(12,852)
Foreign income tax rate differential	(12,379)		(18,918)		(16,364)
Non-deductible expenses	(5,995)		(10,579)		(4,427)
Stock-based compensation expense	(8,321)		(1,385)		(954)
Change in valuation allowance	(19,793)		(595)		390
Foreign financing activities	(5,519)		(4,805)		(11,743)
Uncertain tax positions reserve	45,317		50,059		(38,014)
Tax adjustments related to REIT	107,312		39,164		50,107
Change in deferred tax adjustments	(239)		(1,251)		(136)
Effect of tax rate change on deferred tax assets	(3,126)		(12,297)		—
Other, net	(2,769)		479		(4,323)
Total income tax expense	$	(124,792)	$	(109,224)	$	(146,151)

Schedule of Deferred Tax Assets and Liabilities

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

	2022		2021(1)
Deferred tax assets:
Stock-based compensation expense	$	9,002	$	9,057
Net unrealized losses	3,988		—
Operating lease liabilities	253,005		225,261
Capital lease liabilities	—		13,927
Deferred revenue	13,887		14,429
Goodwill	20,511		30,842
Loss carryforwards and tax credits	142,270		201,132
Others, net	32,543		7,257
Gross deferred tax assets	475,206		501,905
Valuation allowance	(166,594)		(100,746)
Total deferred tax assets, net	308,612		401,159
Deferred tax liabilities:
Net unrealized gains	—		(1,462)
Capital lease liabilities	(8,033)		—
Property, plant and equipment	(221,343)		(262,532)
Right-of-use assets	(256,837)		(233,199)
Deferred income	(28,314)		(33,052)
Intangible assets	(132,816)		(151,385)
Total deferred tax liabilities	(647,343)		(681,630)
Net deferred tax liabilities	$	(338,731)	$	(280,471)

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

Schedule of Changes in Valuation Allowance for Deferred Tax Assets

Changes in the valuation allowance for deferred tax assets for the years ended December 31, 2022, 2021 and 2020 are as follows (in thousands):

	2022		2021		2020
Beginning balance	$	100,746	$	82,344	$	57,812
Amounts from acquisitions	13,458		964		5,777
Amounts recognized into income	22,905		595		(390)
Current increase	36,513		19,539		15,044
Impact of foreign currency exchange	(7,028)		(2,696)		4,101
Ending balance	$	166,594	$	100,746	$	82,344

Schedule of Net operating Loss Carryforwards

Our NOL carryforwards for federal, state and foreign tax purposes which expire, if not utilized, at various intervals from 2023, are outlined below (in thousands):

Expiration Date	Federal (1)		State (1)		Foreign (2) (3)		Total
2023	$	17,395	$	—	$	2,083	$	19,478
2024 to 2026	15,564		—		33,722		49,286
2027 to 2029	6,065		—		28,046		34,111
2030 to 2032	—		767		5,457		6,224
2033 to 2035	1,838		1,339		11,692		14,869
2036 to 2038	5,294		3,636		20,143		29,073
Thereafter	147,010		74,416		452,303		673,729
	$	193,166	$	80,158	$	553,446	$	826,770

(1)The total amount of NOL carryforwards that will not be available to offset our future taxable income after the dividends paid deduction due to Section 382 limitations was $36.7 million for federal and $22.7 million for state.

(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.

Schedule of Reconciliation of Unrecognized Tax Benefits

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

	2022		2021		2020
Beginning balance	$	148,300	$	207,759	$	173,726
Gross increases related to prior year tax positions	1,401		4,547		14,732
Gross decreases related to prior year tax positions	(43,575)		(58,356)		—
Gross increases related to current year tax positions	7,004		10,000		29,149
Decreases resulting from expiration of statute of limitation	(11,969)		(10,561)		(6,518)
Decreases resulting from settlements	(11,924)		(5,089)		(3,330)
Ending balance	$	89,237	$	148,300	$	207,759