v3.25.4
Taxes on Income
 12 Months Ended
Dec. 31, 2025
Income Tax Disclosure [Abstract]  
Taxes on Income Taxes on Income
Income before taxes on income resulting from domestic and foreign operations is as follows:
(in millions)Year Ended December 31,
 202520242023
Domestic operations$3,356 $3,436 $1,899 
Foreign operations2,871 1,872 1,772 
Total income before taxes$6,227 $5,308 $3,671 
The provision for taxes on income consists of the following:
(in millions)Year Ended December 31,
 202520242023
Federal:
Current$909 $740 $559 
Deferred(110)(131)(177)
Total federal799 609 382 
Foreign:
Current448 472 370 
Deferred(52)(161)(150)
Total foreign396 311 220 
State and local:
Current292 252 216 
Deferred(80)(31)(40)
Total state and local212 221 176 
Total provision for taxes $1,407 $1,141 $778 
The Company has elected to prospectively adopt the guidance in ASU No. 2023-09. Refer to Note 1 – Accounting Policies for additional information.
A reconciliation of the U.S. federal statutory income tax amount and rate to our effective income tax amount and rate for financial reporting purposes for the year ended December 31, 2025 is as follows:

(in millions)Year Ended December 31,
 2025
Amount Percent
U.S. Federal Statutory Income Tax Rate$1,308 21.0 %
State & local income taxes, net of federal income tax 1
129 2.1 
Foreign tax effects
United Kingdom(66)(1.1)
Malta
Statutory tax rate differential113 1.8 
Nontaxable income(269)(4.3)
Other foreign jurisdictions48 0.8 
Effects of cross-border tax laws
Subpart F income190 3.0 
Foreign derived intangible income(68)(1.1)
Other86 1.3 
Tax credits(24)(0.4)
Changes in valuation allowances5 0.1 
Nontaxable or nondeductible items23 0.4 
Changes in unrecognized tax benefits(7)(0.1)
Other adjustments
S&P Dow Jones Indices LLC joint venture(65)(1.0)
Other4 0.1 
Effective income tax rate $1,407 22.6 %
1 State and local taxes in New York, California and Virginia make up the majority of the tax effect in this category.

We have elected to recognize the tax on Global Intangible Low Taxed Income (“GILTI”) as a period expense in the year the tax is incurred.

A reconciliation of the U.S. federal statutory income tax rate to our effective income tax rate for financial reporting purposes for the year ended December 31, 2024 and 2023, in accordance with the guidance prior to the adoption of ASU 2023-09, is as follows:

(in millions)Year Ended December 31,
 20242023
U.S. federal statutory income tax rate21.0 %21.0 %
State and local income taxes3.5 3.5 
Foreign operations(4.7)(5.1)
Stock-based compensation(0.3)(0.4)
S&P Dow Jones Indices LLC joint venture(1.1)(1.5)
Tax credits and incentives(0.8)(2.5)
Divestitures0.1 1.8 
Other, net3.8 4.4 
Effective income tax rate 21.5 %21.2 %
We made net income tax payments totaling $1,502 million in 2025, $1,159 million in 2024, and $1,279 million in 2023.
Net income tax payments for the year ended December 31, 2025 consisted of the following:

(in millions)Year ended December 31,
 2025
Federal$722 
State187 
Foreign
United Kingdom170 
Germany105 
Other318 
Total$1,502 
Significant components of the Company’s deferred tax assets and liabilities consisted of the following:

(in millions)December 31,
20252024
Deferred tax assets:
Accrued expenses$128 $114 
Losses and other carryforwards636 695 
Research & Development Expenditures420 350 
Other434 423 
Total deferred tax assets1,618 1,582 
Deferred tax liabilities:
Goodwill and intangible assets(4,321)(4,348)
Other(186)(245)
Total deferred tax liabilities(4,507)(4,593)
Net deferred income tax asset before valuation allowance(2,889)(3,011)
Valuation allowance(302)(313)
Net deferred income tax liability$(3,191)$(3,324)
Reported as:
Non-current deferred tax assets$71 $73 
Non-current deferred tax liabilities(3,262)(3,397)
Net deferred income tax liability$(3,191)$(3,324)
We record valuation allowances against deferred income tax assets when we determine that it is more likely than not that such deferred income tax assets will not be realized based upon all the available evidence. The valuation allowance is primarily related to operating losses and other carryforwards.
A portion of the undistributed earnings of our foreign subsidiaries is indefinitely reinvested in our foreign operations. Accordingly, we have not recorded deferred income taxes related to those earnings. Quantification of the deferred tax liability, if any, associated with indefinitely reinvested earnings is not practicable.
As of December 31, 2025, we had net operating loss and carryforwards of $1,309 million, of which a significant portion has an unlimited carryover period under current law.
A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows:
(in millions)Year ended December 31,
 202520242023
Balance at beginning of year$325 $230 $223 
Additions based on tax positions related to the current year41 76 21 
Additions for tax positions of prior years24 48 10 
Reduction for tax positions of prior years(13)— — 
Reduction for settlements— (11)(11)
Expiration of applicable statutes of limitations(55)(18)(13)
Balance at end of year$322 $325 $230 

The aggregated amount of federal, state and local, and foreign unrecognized tax benefits as of December 31, 2025, 2024 and 2023 was $322 million, $325 million and $230 million, respectively, exclusive of interest and penalties. During the year ended December 31, 2025, the change in unrecognized tax benefits resulted in a net increase of tax expense of $3 million.

We recognize accrued interest and penalties related to unrecognized tax benefits in interest expense and operating-related expense, respectively. During the years ended December 31, 2025, 2024, and 2023, the Company recognized approximately $14 million, $15 million, and $12 million in interest and penalties. In addition to the unrecognized tax benefits, we had accrued interest and penalties associated with unrecognized tax benefits of $79 million, $65 million and $50 million as of December 31, 2025, 2024 and 2023, respectively.

The U.S. federal income tax audits for 2018 through 2024 are in process. During 2025, we completed state and foreign tax audits and, with few exceptions, we are no longer subject to federal, state, or foreign income tax examinations by tax authorities for the years before 2016. The impact to tax expense in 2025, 2024 and 2023 was not material.

We file income tax returns in the U.S. federal jurisdiction and various state and foreign jurisdictions, and we are routinely under audit by many different tax authorities. We believe that our accrual for tax liabilities is adequate for all open audit years based on an assessment of many factors including past experience and interpretations of tax law. This assessment relies on estimates and assumptions and may involve a series of complex judgments about future events. It is possible that tax examinations will be settled prior to December 31, 2026. If any of these tax audit settlements do occur within that period, we would make any necessary adjustments to the accrual for unrecognized tax benefits.

The Organization for Economic Co-operation and Development (“OECD”) introduced an international tax framework under Pillar Two which includes a global minimum tax of 15%, which is implemented through local legislation in participating jurisdictions. The effects of Pillar Two taxes enacted in jurisdictions in which we operate have been reflected in our results and did not have a material impact on our consolidated financial statements.

On January 5, 2026, the OECD issued administrative guidance outlining a framework under which U.S.-parented groups may be excluded from the application of the OECD’s global minimum tax rules. Each member jurisdiction will need to adopt this guidance into local law, and the timing and manner of adoption may vary. We are continuing to monitor developments related to this guidance and will evaluate the impact on our financial statements as additional information becomes available.