Income Taxes

6 Months Ended

Jun. 30, 2025

Income Tax Disclosure [Abstract]

Income Taxes

Income Taxes

We are subject to U.S. federal, state, and foreign income taxes. During the three and six months ended June 30, 2025 and 2024, we recorded the following provisions for income taxes and effective tax rates as compared to our income before provision for income taxes.

	Three Months Ended June 30,				Six Months Ended June 30,
	2025		2024		2025		2024
	(in millions, except percentages)
Income (loss) before provision for income taxes	$	1,283.0	$	(3,391.2)	$	2,013.4	$	(2,112.1)
Provision for income taxes	$	250.1	$	202.4	$	334.2	$	381.9

Effective tax rate 19.5  % (6.0) % 16.6  % (18.1) %

Our effective tax rate for the three and six months ended June 30, 2025 was lower than the U.S. statutory rate primarily due to excess tax benefits related to stock-based compensation and tax credits.

Our effective tax rate for the three and six months ended June 30, 2024 was materially different than the U.S. statutory rate primarily due to the $4.4 billion of non-deductible AIPR&D resulting from our acquisition of Alpine, which drove our pre-tax loss in each of these periods.

We have reviewed the tax positions taken, or to be taken, in our tax returns for all tax years currently open to examination by a taxing authority. As of June 30, 2025 and December 31, 2024, we had $412.1 million and $341.4 million, respectively, of net unrecognized tax benefits, which would affect our tax rate if recognized.

We file U.S. federal income tax returns and income tax returns in various state, local and foreign jurisdictions. We have various income tax audits ongoing at any time throughout the world. Except for jurisdictions where we have net operating losses or tax credit carryforwards, we are no longer subject to any tax assessment from tax authorities for years prior to 2014 in jurisdictions that have a material impact on our consolidated financial statements. In 2023, we came to settlement with the United Kingdom’s HM Revenue & Customs (“HMRC”) with respect to our tax positions for 2015 through 2020 and subsequently received Closure Notices for those periods during the three months ended March 31, 2024. Due to the nature of the adjustments, we are asserting our rights under the U.S./U.K. Income Tax Convention pursuant to the mutual agreement procedures for the relief of double taxation for these matters.

In December 2022, European Union member states reached an agreement to implement the minimum tax component (“Pillar Two”) of the Organization for Economic Co-operation and Development’s (the “OECD’s”), global international tax reform initiative with effective dates of January 1, 2024 and 2025. In July 2023, the OECD published Administrative Guidance proposing certain safe harbors that effectively extend certain effective dates to January 1, 2027. The assessment of our potential 2025 exposure for the global per-country minimum tax of 15%, based on our forecasted 2025 results, is immaterial to our condensed consolidated financial statements as the effective tax rates in most of the jurisdictions in which we operate are above 15%.

In July 2025, the U.S. enacted H.R.1, which includes significant provisions modifying the U.S. tax framework. We are currently evaluating the impact of these legislative changes and will review additional interpretative guidance as it becomes available. These legislative changes could have an impact on our future effective tax rates, tax liabilities, and cash taxes. As required by ASC 740, Income Taxes, the estimated impact of H.R.1 will be included in our financial results in the third quarter of 2025, the period of enactment.