v3.25.4
Income Taxes (Tables)
 12 Months Ended
Dec. 31, 2025
Income Tax Disclosure [Abstract]  
Schedule of Income Before Income Taxes Attributable to Geographic Locations
Income before income taxes is attributable to the following geographic locations for the years ended December 31 (in millions):
202520242023
Domestic $380 $147 $278 
Foreign 1,128 828 846 
Income before income taxes
$1,508 $975 $1,124 
Schedule of Components of Tax Benefit (Expenses) for Income Taxes
The tax expenses for income taxes consisted of the following components for the years ended December 31 (in millions):
202520242023
Current:
Federal $(6)$1 $— 
State and local (2)(3)— 
Foreign (208)(189)(150)
Subtotal
(216)(191)(150)
Deferred:
State and local (1)2 — 
Foreign 57 28 (5)
Subtotal
56 30 (5)
Income tax expense
$(160)$(161)$(155)
Schedule of Income Tax Reconciliation
Income tax benefit (expense) for the year ended December 31, 2025 differed from the amounts computed by applying the U.S. federal income tax rate of 21% to pre-tax income as a result of the following ($ in millions, except percentages):
2025
$%
Federal tax at statutory rate$(317)21.0 %
State and local taxes (1)
(3)0.2 %
Non-deductible or non-taxable items:
REIT status/dividends paid deduction (2)
194 (12.9)%
Other(2)0.1 %
Change in valuation allowance(4)0.3 %
Foreign tax effects:
Canada20 (1.3)%
Singapore
Tax rate differential17 (1.1)%
Other(8)0.5 %
Other foreign jurisdictions(53)3.5 %
Change in unrecognized tax benefits(3)0.2 %
Other adjustments(1)0.1 %
Total income tax expense$(160)10.6 %
(1)State taxes in Virginia contributed to the majority of the tax effect in this category.
(2)The REIT status/dividends paid deduction reconciling item reflects that the Company is generally entitled to a deduction for dividends paid and therefore generally is not subject to U.S. federal corporate income tax on taxable income that is distributed; accordingly, certain permanent differences (e.g., nondeductible executive compensation) do not result in incremental federal income tax expense when fully offset through the dividends paid deduction mechanism.
Income tax benefit (expense) for the years ended December 31, 2024 and 2023 differed from the amounts computed by applying the U.S. federal income rate of 21% to pre-tax income as a result of the following (in millions):
20242023
Federal tax at statutory rate $(205)$(236)
State and local tax expense(1)— 
Foreign income tax rate differential (12)(14)
Non-deductible expenses (10)(6)
Stock-based compensation expense (8)(9)
Change in valuation allowance(72)(32)
Foreign financing activities(2)(4)
Uncertain tax positions reserve 11 21 
Tax adjustments related to REIT130 132 
Change in deferred tax adjustments1 (3)
Effect of tax rate change on deferred tax assets— (2)
Other, net 7 (2)
Total income tax expense
$(161)$(155)
Schedule of Deferred Tax Assets and Liabilities
The types of temporary differences that give rise to significant portions of our deferred tax assets and liabilities are set out below as of December 31 (in millions):
20252024
Deferred tax assets:
Stock-based compensation expense $11 $10 
Net unrealized losses26 12 
Operating lease liabilities233 217 
Finance lease liabilities36 — 
Deferred revenue15 11 
Loss carryforwards and tax credits304 253 
Others, net62 25 
Gross deferred tax assets
687 528 
Valuation allowance (285)(277)
Total deferred tax assets, net 402 251 
Deferred tax liabilities:
Finance lease liabilities— (13)
Property, plant and equipment(305)(200)
Right-of-use assets(235)(220)
Deferred income(6)(5)
Goodwill(40)(17)
Intangible assets (83)(87)
Total deferred tax liabilities
(669)(542)
Net deferred tax liabilities$(267)$(291)
Schedule of Changes in Valuation Allowance for Deferred Tax Assets
Changes in the valuation allowance for deferred tax assets for the years ended December 31 are as follows (in millions):
202520242023
Beginning balance $277 $221 $167 
Amounts from acquisitions
— — 10 
Amounts recognized into income
(26)6 (2)
Current increase26 57 44 
Impact of foreign currency exchange
8 (7)2 
Ending balance $285 $277 $221 
Schedule of Net operating Loss Carryforwards
Our net operating loss carryforwards for federal, state and foreign tax purposes which expire, if not utilized, at various intervals from 2026, are outlined below (in millions):
Expiration DateFederalStateForeign
Total (1) (2)
2026$1 $— $12 $13 
2027 to 20291 — 73 74 
2030 to 2032— 1 38 39 
2033 to 20351 — 69 70 
2036 to 20382 — 16 18 
2039 to 2041— 21 74 95 
Thereafter194 92 727 1,013 
$199 $114 $1,009 $1,322 
(1)In certain jurisdictions, the net operating loss carryforwards can only be used to offset a percentage of taxable income in a given year.
(2)If certain substantial changes in the entity's ownership occur, there may be a limitation on the amount of the carryforwards that can be utilized.
Schedule of Reconciliation of Unrecognized Tax Benefits
The beginning and ending balances of our unrecognized tax benefits are reconciled below for the years ended December 31 (in millions):
202520242023
Beginning balance$57 $70 $89 
Gross increases related to prior year tax positions
7 — 3 
Gross decreases related to prior year tax positions
— (12)(17)
Gross increases related to current year tax positions
5 7 5 
Decreases resulting from expiration of statute of limitation
(7)(7)(10)
Decreases resulting from settlements
— (1)— 
Ending balance$62 $57 $70 
Schedule of Cash Flow Supplemental Disclosures
We applied ASU 2023-09 on a prospective basis as discussed in Note 1. Accordingly, the income taxes paid by jurisdiction (net of refunds received) in the table below provide the disclosures required by ASU 2023-09 for the year ended December 31, 2025 (in millions):
2025
US federal$(1)
US states2
Foreign
Brazil26
Singapore68
Japan23
Australia23
Netherlands31
Other35
Total foreign206 
Total income taxes paid (net of refunds received) (1)
$207 
(1)Includes withholding tax expense.