Income Taxes (Tables)

12 Months Ended

Dec. 31, 2022

Components of deferred tax assets and liabilities

The components of the Company’s deferred tax assets and liabilities were as follows:


	December 31,
(in millions)	2022		2021
Deferred tax assets:
Stock-based compensation expense	$	8.1	$	10.6
Accrued expenses	86.1		86.2
Financing and operating leasing obligations	2,619.3		2,351.3
Unrecognized tax benefits	9.8		8.9
Investments in and advances to unconsolidated affiliates	13.0		—
Discount on convertible notes	0.4		—
Net operating losses, interest limitation and tax credit carryforwards	112.7		115.7
Gross deferred tax assets	2,849.4		2,572.7
Less: Valuation allowance	(31.2)		(124.3)
Net deferred tax assets	2,818.2		2,448.4
Deferred tax liabilities:
Property and equipment, not subject to the Master Leases	(99.1)		(65.6)
Property and equipment, subject to the Master Leases	(925.0)		(992.9)
Investments in and advances to unconsolidated affiliates	—		(6.8)
Discount on convertible notes	—		(18.1)

Intangible assets	(263.7)		(284.8)
Lease right of use assets	(1,564.3)		(1,269.3)
Net deferred tax liabilities	(2,852.1)		(2,637.5)
Long-term deferred tax liabilities, net	$	(33.9)	$	(189.1)

Components of income before income tax expense

The domestic and foreign components of income (loss) before income taxes for the years ended December 31, 2022, 2021, and 2020 were as follows:


	For the year ended December 31,
(in millions)	2022		2021		2020
Domestic	$	295.3	$	606.0	$	(834.0)
Foreign	(120.0)		(66.9)		(0.2)
Total	$	175.3	$	539.1	$	(834.2)

Schedule of provision for income taxes

The components of income tax benefit (expense) for the years ended December 31, 2022, 2021, and 2020 were as follows:


	For the year ended December 31,
(in millions)	2022		2021		2020
Current tax benefit (expense)
Federal	$	(89.0)	$	(100.0)	$	47.0
State	(15.3)		(23.1)		0.2
Foreign	—		—		(0.4)
Total current	(104.3)		(123.1)		46.8
Deferred tax benefit (expense)
Federal	33.7		(11.9)		103.6
State	78.5		13.3		14.7
Foreign	38.5		3.1		—
Total deferred	150.7		4.5		118.3
Total income tax benefit (expense)	$	46.4	$	(118.6)	$	165.1

Reconciliation of the statutory federal income tax rate to the actual effective income tax rate

The following table reconciles the statutory federal income tax rate to the actual effective income tax rate, and related amounts of income tax benefit (expense), for the years ended December 31, 2022, 2021, and 2020:


	For the year ended December 31,
	2022			2021			2020
(in millions, except tax rates)	Amount			Amount			Amount
Amount of pre-tax income
Federal statutory rate	$	(36.8)		$	(113.2)		$	175.2
State and local income taxes, net of federal benefits	(5.2)			(7.7)			12.1
Tax law change	(10.8)			—			—
Nondeductible expenses	(7.8)			(13.3)			(2.6)
Goodwill impairment losses	—			—			(19.0)
Compensation	(6.2)			6.5			20.5
Foreign	0.9			0.9			(0.4)
Valuation allowance	113.4			(5.9)			(32.7)
Tax credits	4.6			5.8			10.0
Equity investment write-off	—			11.3			—
Other	(5.7)			(3.0)			2.0
Income tax benefit (expense)	$	46.4		$	(118.6)		$	165.1
Effective Tax Rate	(26.5)		%	22.0		%	19.8		%

Reconciliation of unrecognized tax benefits

A reconciliation of the beginning and ending amounts of unrecognized tax benefits is as follows:


(in millions)	Unrecognized tax benefits
Unrecognized tax benefits as of January 1, 2020	$	36.0
Additions based on prior year positions	1.2
Decreases due to settlements and/or reduction in reserves	(0.9)
Unrecognized tax benefits as of December 31, 2020	36.3
Additions based on prior year positions	3.8
Decreases due to settlements and/or reduction in reserves	(0.1)
Unrecognized tax benefits as of December 31, 2021	40.0
Additions based on prior year positions	2.9
Decreases due to settlements and/or reduction in reserves	(0.2)
Unrecognized tax benefits as of December 31, 2022	$	42.7