INCOME TAXES (Tables)
|
12 Months Ended |
Dec. 31, 2024 |
|---|
| INCOME TAXES [Abstract] |
|
| Schedule of Components of (Loss) Income Before Income Taxes |
(Loss) income before income taxes includes the following components (in thousands):
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Year Ended December 31, |
|
|
|
2024 |
|
|
2023 |
|
|
2022 |
|
United States |
|
$ |
(265,532 |
) |
|
$ |
124,736 |
|
|
$ |
371,382 |
|
Foreign |
|
|
55,327 |
|
|
|
42,247 |
|
|
|
(3,297 |
) |
Total (loss) income before income taxes |
|
$ |
(210,205 |
) |
|
$ |
166,983 |
|
|
$ |
368,085 |
|
|
| Summary of Components Benefit from Provision for Income Taxes |
The income tax provision consists of the following (in thousands):
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Year Ended December 31, |
|
|
|
2024 |
|
|
2023 |
|
|
2022 |
|
Current: |
|
|
|
|
|
|
|
|
|
U.S. federal, state and local |
|
$ |
38,510 |
|
|
$ |
5,694 |
|
|
$ |
(2,503 |
) |
Foreign |
|
|
68,162 |
|
|
|
28,280 |
|
|
|
24,730 |
|
Total Current |
|
|
106,672 |
|
|
|
33,974 |
|
|
|
22,227 |
|
Deferred: |
|
|
|
|
|
|
|
|
|
U.S. federal, state and local |
|
|
(62,439 |
) |
|
|
(7,883 |
) |
|
|
(1,234 |
) |
Foreign |
|
|
(6,978 |
) |
|
|
7,105 |
|
|
|
(5,098 |
) |
Total Deferred |
|
|
(69,417 |
) |
|
|
(778 |
) |
|
|
(6,332 |
) |
Total provision for income taxes |
|
$ |
37,255 |
|
|
$ |
33,196 |
|
|
$ |
15,895 |
|
|
| Schedule of Effective Income Tax Rate Based on Consolidated Statements of Operations Differs From U.S. Statutory Federal Income Tax Rate |
The Company’s effective tax rate differs from the U.S. federal statutory rate primarily due to partnership income not subject to income tax and withholding taxes in foreign jurisdictions that are not based on net income. The effective tax rate based on the actual provision shown in the combined statements of operations differs from the U.S. statutory federal income tax rate as follows (in thousands):
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Year Ended December 31, |
|
|
|
2024 |
|
|
2023 |
|
|
2022 |
|
U.S. statutory federal income tax of 21% |
|
$ |
(44,142 |
) |
|
$ |
35,066 |
|
|
$ |
77,296 |
|
Partnership income not subject to tax |
|
|
40,115 |
|
|
|
(60,382 |
) |
|
|
(91,436 |
) |
Tax impact of foreign operations |
|
|
42,970 |
|
|
|
42,898 |
|
|
|
28,105 |
|
UK ORIP Tax |
|
|
2,894 |
|
|
|
1,215 |
|
|
|
859 |
|
Provision to return |
|
|
1,333 |
|
|
|
2,145 |
|
|
|
(983 |
) |
Permanent differences |
|
|
2,863 |
|
|
|
2,029 |
|
|
|
(4,404 |
) |
Nondeductible officers compensation |
|
|
7,943 |
|
|
|
4,465 |
|
|
|
— |
|
Equity method investments |
|
|
435 |
|
|
|
(2,686 |
) |
|
|
(2,391 |
) |
Third party ownership reversal |
|
|
— |
|
|
|
(167 |
) |
|
|
(1,087 |
) |
Opening balance remeasurement |
|
|
— |
|
|
|
4,270 |
|
|
|
— |
|
Valuation allowance |
|
|
20,551 |
|
|
|
(1,180 |
) |
|
|
(2,141 |
) |
Unrecognized tax benefits |
|
|
2,428 |
|
|
|
3,836 |
|
|
|
9,576 |
|
U.S. state and local taxes |
|
|
(7,921 |
) |
|
|
176 |
|
|
|
788 |
|
Foreign tax credit, net of expiration |
|
|
(25,606 |
) |
|
|
— |
|
|
|
— |
|
Other |
|
|
(6,608 |
) |
|
|
1,511 |
|
|
|
1,713 |
|
Total provision for income taxes |
|
$ |
37,255 |
|
|
$ |
33,196 |
|
|
$ |
15,895 |
|
|
| Summary of Principal Components of Deferred Tax Assets and Liabilities |
Principal components of deferred tax assets and liabilities are as follows (in thousands):
|
|
|
|
|
|
|
|
|
|
|
As of December 31, |
|
|
|
2024 |
|
|
2023 |
|
Deferred tax assets: |
|
|
|
|
|
|
Compensation and severance |
|
$ |
14,382 |
|
|
$ |
17,776 |
|
Net operating loss, capital loss and tax credits carried forward |
|
|
50,853 |
|
|
|
38,021 |
|
Lease liability |
|
|
35,404 |
|
|
|
38,233 |
|
Accrued expenses |
|
|
30,880 |
|
|
|
— |
|
Other |
|
|
6,077 |
|
|
|
10,380 |
|
Total gross deferred tax assets |
|
|
137,596 |
|
|
|
104,410 |
|
Less: valuation allowance |
|
|
(36,616 |
) |
|
|
(16,166 |
) |
Net deferred tax assets |
|
|
100,980 |
|
|
|
88,244 |
|
|
|
|
|
|
|
|
Deferred tax liabilities: |
|
|
|
|
|
|
Property, buildings, and equipment |
|
|
(35,022 |
) |
|
|
(34,701 |
) |
Loss contracts |
|
|
(7,793 |
) |
|
|
(13,547 |
) |
Intangible assets |
|
|
(374,606 |
) |
|
|
(416,618 |
) |
Lease asset |
|
|
(34,201 |
) |
|
|
(37,101 |
) |
Investments |
|
|
(7,755 |
) |
|
|
(6,681 |
) |
Other liabilities |
|
|
— |
|
|
|
(2,445 |
) |
Net deferred tax liabilities |
|
|
(459,377 |
) |
|
|
(511,093 |
) |
|
|
|
|
|
|
|
Total net deferred tax (liabilities) assets |
|
$ |
(358,397 |
) |
|
$ |
(422,849 |
) |
|
| Schedule of Aggregate Changes to The Liability for Unrecognized Tax Benefits, Excluding Interest and Penalties |
The Company had unrecognized tax benefits of $38.0 million, $39.3 million and $34.7 million, respectively, as of December 31, 2024, 2023 and 2022. The aggregate changes to the liability for unrecognized tax benefits, excluding interest and penalties, were as follows (in thousands):
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Year Ended December 31, |
|
|
|
2024 |
|
|
2023 |
|
|
2022 |
|
Beginning balance |
|
$ |
39,250 |
|
|
$ |
34,749 |
|
|
$ |
29,656 |
|
Acquisitions |
|
|
— |
|
|
|
2,549 |
|
|
|
— |
|
Gross increases |
|
|
10,042 |
|
|
|
9,268 |
|
|
|
7,939 |
|
Gross decreases |
|
|
(4,335 |
) |
|
|
(274 |
) |
|
|
(743 |
) |
Lapse of statue of limitations |
|
|
(6,946 |
) |
|
|
(7,472 |
) |
|
|
(1,122 |
) |
Translation adjustments |
|
|
(49 |
) |
|
|
430 |
|
|
|
(981 |
) |
Ending balance |
|
$ |
37,962 |
|
|
$ |
39,250 |
|
|
$ |
34,749 |
|
|