Income Taxes

6 Months Ended

Jun. 30, 2024

Income Tax Disclosure [Abstract]

Income Taxes

10. Income Taxes

The Company’s provision (benefit) for income taxes was $69.5 million and $(7.3) million for the three months ended

June 30, 2024 and 2023, respectively, and $91.4 million and $27.0 million for the six months ended June 30, 2024 and 2023,

respectively. The Company’s effective tax rate was approximately 32% and 10% for the three months ended June 30, 2024 and

2023, respectively, and 27% and 30% for the six months ended June 30, 2024 and 2023, respectively. The effective tax rate for

the six months ended June 30, 2024 and 2023 primarily comprised the 21% U.S. federal corporate income tax rate, the impact

of U.S. state and foreign income taxes, and disallowed executive compensation, partially offset by non-controlling interest and

equity-based compensation deductions. The effective tax rate for the six months ended June 30, 2024 also includes an increase

related to other non-deductible expenses. As of June 30, 2024 and December 31, 2023, the Company had federal, state, local

and foreign taxes payable of $46.3 million and $46.9 million, respectively, which is recorded as a component of accounts

payable, accrued expenses and other liabilities on the accompanying condensed consolidated balance sheets.

In the normal course of business, the Company is subject to examination by federal and certain state, local and foreign tax

regulators. With a few exceptions, as of June 30, 2024, the Company’s U.S. federal income tax returns for the years 2020

through 2022 are open under the normal three-year statute of limitations and therefore subject to examination. State and local

tax returns are generally subject to audit from 2018 to 2022. Foreign tax returns are generally subject to audit from 2011 to

2023. Certain of the Company’s affiliates are currently under audit by federal, state and foreign tax authorities.

The Company does not believe that the outcome of the audits will require it to record material reserves for uncertain tax

positions or that the outcome will have a material impact on the consolidated financial statements. The Company does not

believe that it has any tax positions for which it is reasonably possible that the total amounts of unrecognized tax benefits will

significantly increase or decrease within the next twelve months.

On August 16, 2022, the Inflation Reduction Act of 2022 (the “IRA”) was signed into law. The IRA enacted a 15%

CAMT on the “adjusted financial statement income” of certain large corporations, which became effective on January 1, 2023.

The Company does not expect the IRA to have a material impact to its provision for income taxes given that any current year

payments that would be made under CAMT would be permitted to be carried forward and used as credits in future years

resulting in a deferred tax benefit. The Company will continue to monitor as additional guidance is released by U.S. Department

of the Treasury, the IRS, and other standard-setting bodies.

On December 27, 2023, the State of New York issued final regulations that implemented comprehensive franchise tax

reform for corporations, banks, and insurance companies. This did not have a material impact to the Company’s consolidated

financial statements. The Company will continue to monitor as additional guidance is released by the State of New York.

In October 2021, the OECD introduced a 15% global minimum tax under the Pillar Two GloBE model rules. There are a

number of key provisions under the rules that are being phased in during 2024 and 2025. Several OECD member countries have

enacted the tax legislation based on certain elements of these rules that became effective on January 1, 2024, and additional

countries have drafted or announced an intent to implement legislation. While the Company does not expect Pillar Two to have

a material impact to its provision for income taxes for 2024, the rules remain subject to significant negotiation and potential

change, and the timing and ultimate impact of any such changes on our tax obligations are uncertain. The Company will

continue to monitor as additional countries enact legislation, new parts of the regime come into force or additional guidance is

released by the OECD and other standard-setting bodies.