Income Taxes (Tables)

12 Months Ended

Dec. 31, 2024

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)	2024		2023
Deferred tax assets:
Stock-based compensation expense	$	6.7	$	7.6
Accrued expenses	156.5		128.6
Financing and operating leasing obligations	2,185.6		2,292.8
Unrecognized tax benefits	9.5		9.9
Investments in and advances to unconsolidated affiliates	15.5		15.2
Discount on convertible notes	0.2		0.3
Net operating losses and tax credit carryforwards	171.8		138.4
Capital loss carryforwards	127.2		126.1
Interest limitation carryforwards	26.7		12.1
Gross deferred tax assets	2,699.7		2,731.0
Less: Valuation allowance	(268.0)		(210.5)
Net deferred tax assets	2,431.7		2,520.5
Deferred tax liabilities:
Property and equipment, not subject to the Master Leases	(73.6)		(123.9)
Property and equipment, subject to the Master Leases	(593.4)		(635.0)



Intangible assets	(298.4)		(259.1)
Lease right-of-use assets	(1,527.3)		(1,620.1)
Net deferred tax liabilities	(2,492.7)		(2,638.1)
Long-term deferred tax liabilities, net	$	(61.0)	$	(117.6)

Schedule of Components of Income Before Income Tax Benefit (Expense)

The domestic and foreign components of income (loss) before income taxes were as follows:


	For the year ended December 31,
(in millions)	2024		2023		2022
Domestic	$	(179.3)	$	(382.6)	$	295.3
Foreign	(162.0)		(117.0)		(120.0)
Total	$	(341.3)	$	(499.6)	$	175.3

Schedule of Provision for Income Taxes

The components of income tax benefit were as follows:


	For the year ended December 31,
(in millions)	2024		2023		2022
Current tax benefit (expense)
Federal	$	(25.6)	$	(20.8)	$	(89.0)
State	(4.7)		(4.9)		(15.3)
Foreign	0.2		—		—
Total current	(30.1)		(25.7)		(104.3)
Deferred tax benefit (expense)
Federal	53.9		13.2		33.7
State	4.0		22.8		78.5
Foreign	0.2		(2.1)		38.5
Total deferred	58.1		33.9		150.7
Total income tax benefit	$	28.0	$	8.2	$	46.4

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:


	For the year ended December 31,
	2024			2023			2022
(in millions, except tax rates)
Amount of pre-tax income
Federal statutory rate	$	71.7		$	105.0		$	(36.8)
State and local income taxes, net of federal benefits	17.7			16.1			(5.2)
Tax law change	—			—			(10.8)
Nondeductible expenses	(4.0)			(48.5)			(7.8)

Compensation	(6.8)			(7.2)			(6.2)
Foreign	4.4			1.9			0.9
Valuation allowance	(61.1)			(56.4)			113.4
Tax credits	5.9			4.9			4.6
Equity investment write-off	—			(2.6)			—
Other	0.2			(5.0)			(5.7)
Income tax benefit	$	28.0		$	8.2		$	46.4
Effective Tax Rate	8.2		%	1.7		%	(26.5)		%

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, 2022	$	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
Additions based on prior year positions	1.4
Decreases due to settlements and/or reduction in reserves	(3.1)
Unrecognized tax benefits as of December 31, 2024	$	41.9