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INCOME TAXES
6 Months Ended
Jun. 30, 2025
Income Tax Disclosure [Abstract]  
INCOME TAXES INCOME TAXES
The Company's quarterly income tax provision is measured using an estimate of its consolidated annual effective tax rate, which includes the impact of foreign withholding tax accruals and uncertain tax positions, adjusted for discrete items, within the periods presented. The comparison of the Company's income tax provision between periods can be significantly impacted by the level and mix of earnings, losses by tax jurisdiction and discrete items.

For the three months ended June 30, 2025, the Company recognized income tax expense of $15.8 million as compared to a $17.5 million benefit in the same period for 2024. Income tax expense for the three months ended June 30, 2025, includes a continued U.S. benefit related to claiming foreign tax credits, a recurring benefit from a U.S. tax deduction related to FDII and the impact of changes to the level and mix of earnings.

For the six months ended June 30, 2025, the Company recognized income tax expense of $33.6 million as compared to a $4.0 million benefit in the same period for 2024. Income tax expense for the six months ended June 30, 2025, includes a continued U.S. benefit related to claiming foreign tax credits and a recurring benefit from a U.S. tax deduction related to FDII, partially offset by a $7.7 million multi-year tax settlement and the impact of changes to the level and mix of earnings.

On February 28, 2025, the Company completed the MGS Transaction and realized a gain on sale of $70.9 million as of June 30, 2025. This transaction resulted in a nominal tax impact, which reduced the effective tax rate primarily due to the realization of a deferred tax asset and an offsetting release of a valuation allowance.

Income tax benefit for the three and six months ended June 30, 2024, included a continued U.S. benefit related to claiming foreign tax credits consistent with our election in the fourth quarter of 2023, a recurring benefit from a U.S. tax deduction related to FDII, the negative impact of GILTI and the impact of changes to the level and mix of earnings.

The three and six months ended June 30, 2024 also includes a benefit associated with the release of valuation allowances of $35.9 million and $37.1 million, respectively. The benefit was associated with the release of valuation allowances previously recorded against certain U.K. tax attribute carryforwards, primarily consisting of net operating loss carryforwards and interest carryforwards. The valuation allowances were released due to improved profitability in the Company's UK businesses.

On July 4, 2025, The One Big Beautiful Bill Act (“OBBBA”) was enacted, extending many of the expiring tax provisions of the TCJA while adding, modifying and altering numerous provisions. The Company is currently evaluating the impacts of the OBBBA on its consolidated financial statements.