Income Taxes (Tables)

12 Months Ended

Dec. 31, 2023

Schedule of 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)	2023		2022
Deferred tax assets:
Stock-based compensation expense	$	7.6	$	8.1
Accrued expenses	128.6		86.1
Financing and operating leasing obligations	2,292.8		2,619.3
Unrecognized tax benefits	9.9		9.8
Investments in and advances to unconsolidated affiliates	15.2		13.0
Discount on convertible notes	0.3		0.4
Net operating losses and tax credit carryforwards	138.4		108.2
Capital loss carryforwards	126.1		4.5
Interest limitation carryforwards	12.1		—
Gross deferred tax assets	2,731.0		2,849.4
Less: Valuation allowance	(210.5)		(31.2)
Net deferred tax assets	2,520.5		2,818.2
Deferred tax liabilities:
Property and equipment, not subject to the Master Leases	(123.9)		(99.1)
Property and equipment, subject to the Master Leases	(635.0)		(925.0)



Intangible assets	(259.1)		(263.7)
Lease right-of-use assets	(1,620.1)		(1,564.3)
Net deferred tax liabilities	(2,638.1)		(2,852.1)
Long-term deferred tax liabilities, net	$	(117.6)	$	(33.9)

Schedule of Components of Income Before Income Tax Expense

The domestic and foreign components of income (loss) before income taxes for the years ended December 31, 2023, 2022, and 2021 were as follows:


	For the year ended December 31,
(in millions)	2023		2022		2021
Domestic	$	(382.6)	$	295.3	$	606.0
Foreign	(117.0)		(120.0)		(66.9)
Total	$	(499.6)	$	175.3	$	539.1

Schedule of Provision for Income Taxes

The components of income tax benefit (expense) for the years ended December 31, 2023, 2022, and 2021 were as follows:


	For the year ended December 31,
(in millions)	2023		2022		2021
Current tax expense
Federal	$	(20.8)	$	(89.0)	$	(100.0)
State	(4.9)		(15.3)		(23.1)

Total current	(25.7)		(104.3)		(123.1)
Deferred tax benefit (expense)
Federal	13.2		33.7		(11.9)
State	22.8		78.5		13.3
Foreign	(2.1)		38.5		3.1
Total deferred	33.9		150.7		4.5
Total income tax benefit (expense)	$	8.2	$	46.4	$	(118.6)

Schedule of 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, 2023, 2022, and 2021:


	For the year ended December 31,
	2023			2022			2021
(in millions, except tax rates)
Amount of pre-tax income
Federal statutory rate	$	105.0		$	(36.8)		$	(113.2)
State and local income taxes, net of federal benefits	16.1			(5.2)			(7.7)
Tax law change	—			(10.8)			—
Nondeductible expenses	(48.5)			(7.8)			(13.3)

Compensation	(7.2)			(6.2)			6.5
Foreign	1.9			0.9			0.9
Valuation allowance	(56.4)			113.4			(5.9)
Tax credits	4.9			4.6			5.8
Equity investment write-off	(2.6)			—			11.3
Other	(5.0)			(5.7)			(3.0)
Income tax benefit (expense)	$	8.2		$	46.4		$	(118.6)
Effective Tax Rate	1.7		%	(26.5)		%	22.0		%

Schedule of 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, 2021	$	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
Additions based on prior year positions	2.2
Decreases due to settlements and/or reduction in reserves	(1.3)
Unrecognized tax benefits as of December 31, 2023	$	43.6