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Income Taxes
12 Months Ended
Dec. 31, 2023
Income Tax Disclosure [Abstract]  
Income Taxes
6.
INCOME TAXES

The following table presents the U.S. and non‑U.S. components of income (loss) before income tax expense:

 

 

 

For the Year Ended December 31,

 

 

2023

 

2022

 

2021

U.S.

 

$

(24,267)

 

$

164,623

 

$

468,725

Non-U.S.

 

 

(4,880)

 

 

51,697

 

 

67,588

Income (loss) before income taxes

 

$

(29,147)

 

$

216,320

 

$

536,313

 

The current and deferred components of the income tax provision for the years ended December 31, 2023, 2022 and 2021 are as follows:

 

 

 

For the Year Ended December 31,

 

 

2023

 

2022

 

2021

Current income taxes:

 

 

 

 

 

 

 

 

 

Federal

 

$

1,425

 

$

8,659

 

$

63,979

State and Local

 

 

(183)

 

 

6,290

 

 

15,875

Foreign

 

 

1,419

 

 

5,901

 

 

10,619

 

 

 

 

 

 

 

 

 

 

Deferred income taxes:

 

 

 

 

 

 

 

 

 

Federal

 

$

(2,471)

 

$

20,308

 

$

20,811

State and Local

 

 

(125)

 

 

4,788

 

 

4,295

Foreign

 

 

(1,696)

 

 

1,692

 

 

(2,244)

Total

 

$

(1,631)

 

$

47,638

 

$

113,335

 

 

The total provision for income taxes differs from the amount which would be computed by applying the appropriate statutory rate to income before income taxes as follows:

 

 

 

For the Year Ended December 31,

 

 

2023

 

2022

 

2021

Reconciliation of federal statutory tax rates

 

 

 

 

 

 

 

 

 

U.S. statutory tax rate

 

21.0

%

 

21.0

%

 

21.0

%

Increase (decrease) due to state and local taxes

 

1.3

%

 

2.3

%

 

3.6

%

Rate benefit as a U.S. limited partnership/flow through

 

-1.8

%

 

-1.8

%

 

-2.3

%

Excess tax benefit from equity compensation delivery

 

9.2

%

 

-2.6

%

 

-3.4

%

Foreign taxes

 

3.3

%

 

0.8

%

 

1.3

%

Non-deductible expenses

 

-20.2

%

 

1.9

%

 

2.2

%

Regulatory settlements

 

-6.7

%

 

0.0

%

 

0.0

%

Return to provision

 

-4.0

%

 

1.1

%

 

-0.3

%

Other

 

3.4

%

 

-0.8

%

 

-1.0

%

Effective income tax rate

 

5.5

%

 

21.9

%

 

21.1

%

 

Deferred income taxes reflect the net effect of temporary differences between the tax basis of an asset or liability and its reported amount in the Company’s consolidated statements of financial condition. These temporary differences result in taxable or deductible amounts in future years.

The Company recorded an increase in the net deferred tax asset of $7,589 for the year ended December 31, 2023. The significant components of deferred tax assets and liabilities included on the Company’s consolidated statements of financial condition are as follows:

 

 

 

For the Year Ended December 31,

 

 

2023

 

2022

Net operating loss

 

$

40,140

 

$

8,679

Step-up in tax basis in Group LP assets

 

 

332,261

 

 

361,544

Deferred compensation

 

 

75,168

 

 

66,228

Lease liability

 

 

49,505

 

 

44,326

Other

 

 

7,869

 

 

9,467

Net deferred tax asset before valuation allowance

 

 

504,943

 

 

490,244

Valuation allowance on NOL and other

 

 

(14,870)

 

 

(11,563)

Deferred tax asset

 

$

490,073

 

$

478,681

 

 

 

 

 

 

 

Right-of-use asset

 

$

(39,409)

 

$

(34,972)

Other

 

 

(13,426)

 

 

(14,060)

Deferred tax liability

 

$

(52,835)

 

$

(49,032)

 

 

 

 

 

 

 

Net deferred tax asset

 

$

437,238

 

$

429,649

As of December 31, 2023, the Company had accumulated net operating loss carryforwards related to its operations of approximately $164,326 for which it has recorded a deferred tax asset of $40,140. Approximately $163,071 of the operating losses (or $39,814 of the deferred tax asset) has an indefinite life and $1,255 of the operating losses (or $326 of the deferred tax asset) will expire in 2031.

The Company’s operations are generally comprised of entities that are organized as limited liability companies and limited partnerships. For U.S. federal income tax purposes, taxes related to income earned by these entities generally represent obligations of their interest holders. The Company is subject to certain foreign, state and local entity-level taxes (for example, the New York City Unincorporated Business Tax ("UBT")). In addition, the Company is subject to U.S. corporate federal, state and local income tax on its allocable share of results of operations from Group LP.

During the year ended December 31, 2023, Group LP was selected for examination by the Internal Revenue Service for the tax year ended December 31, 2020. The Company’s tax years for 2022, 2021 and

2020 are generally subject to examination by the tax authorities. Tax examinations are monitored on an ongoing basis and adjustments to tax liabilities are made as appropriate.

The Company has no unrecognized tax benefits for the periods ended December 31, 2023, 2022 and 2021.