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INCOME TAXES
 12 Months Ended
Dec. 31, 2025
Income Tax Disclosure [Abstract]  
INCOME TAXES INCOME TAXES
During the years ended December 31, 2025 and 2024, the Company’s income (loss) from continuing operations before income taxes of $229,559 and $(900,396) includes a United States component of income (loss) from continuing operations before income taxes of $219,246 and $(908,886) and a foreign component comprised of income from continuing operations before income taxes of $10,313 and $8,490, respectively. The Company will recognize any U.S. income tax expense it may incur on global intangible low tax income as income tax expense in the period in which the tax is incurred. The Company’s (benefit from) provision for income taxes consists of the following during the years ended December 31, 2025 and 2024:
Year Ended December 31,
20252024
Current:
Federal$(14,853)$— 
State2,280 300 
Foreign(8,593)2,515 
Total current provision(21,166)2,815 
Deferred:  
Federal8,745 18,154 
State3,298 632 
Foreign(762)412 
Total deferred11,281 19,198 
Total (benefit from) provision for income taxes$(9,885)$22,013 
Net income tax payments during the year ended December 31, 2025 are as follows:
Year Ended December 31, 2025
Federal$(605)
States and local:
Alabama292 
California709 
New York552 
Tennessee220 
Texas247 
Other states and local744 
Total states and local2,764 
Foreign:
Australia241 
Canada611 
India239 
United Kingdom1,904 
Other foreign73 
Total foreign3,068 
Total net income tax payments$5,227 
A reconciliation of the federal statutory rate of 21.0% to the effective tax rate for income from continuing operations before income taxes is as follows in accordance with the adoption of ASU 2023-09, which became effective in the year ended December 31, 2025:

Year Ended December 31, 2025
AmountRate
Federal statutory rate$48,208 21.0%
Adjustments resulting from the tax effect of:
State and local income tax, net of federal income tax(1)
3,486 1.5%
Foreign Tax Effects:
Israel:
Changes in valuation allowance(61,616)(26.8%)
Changes in net operating loss carryforwards and other attributes due to dissolution61,616 26.8%
Other foreign:
Foreign tax differential(782)(0.3%)
Changes in valuation allowance(47)—%
Effect of cross-border tax laws:
Global intangible low-taxed income and Pillar II961 0.4%
Changes in valuation allowance(29,451)(12.9%)
Nontaxable or nondeductible items:
Share-based compensation(1,270)(0.6%)
Goodwill and impairment of intangibles3,226 1.4%
Gain on sale from disposition of businesses(2,826)(1.2%)
Executive compensation limitation3,158 1.4%
Other416 0.2%
Change in unrecognized tax benefits(10,842)(4.8%)
Other:
Intangible assets(8,023)(3.5%)
Fair value adjustments on investments(8,326)(3.6%)
Fair value adjustments on debt instruments(3,551)(1.5%)
Other adjustments(4,222)(1.8%)
Effective income tax benefit rate$(9,885)(4.3%)
(1)
During the year ended December 31, 2025, the tax effect in this category was primarily driven by state taxes in New York, California, and Virginia (greater than 50 percent).
The effective income tax benefit rate is less than the federal statutory rate, primarily due to the full valuation allowance for deferred income taxes and the benefit recorded during the year ended December 31, 2025 for the release of uncertain tax positions a) in Israel in the amount of $10,530 and b) transfer pricing related to Targus pre-acquisition by BRCGH of $5,649.
A reconciliation of the federal statutory rate of 21.0% to the effective tax rate for loss from continuing operations before income taxes is as follows during the year ended December 31, 2024:
Year Ended December 31, 2024
Provision for income taxes at federal statutory rate(21.0%)
State income taxes, net of federal benefit(6.3%)
Employee share-based compensation0.5%
Goodwill and impairment of intangibles0.8%
Provision true-up1.5%
Change in valuation allowance27.4%
Other(0.5%)
Effective income tax rate2.4%
Deferred income tax assets (liabilities) consisted of the following as of December 31, 2025 and 2024:
December 31,
20252024
Deferred tax assets:
Accrued liabilities and other$5,478 $9,682 
Loans receivable and investments8,521 144,008 
Other7,999 1,583 
Lease liabilities10,546 21,999 
Deferred revenue5,273 7,717 
Long-term debt19,180 — 
Share-based payments2,094 3,464 
Credit carryforwards793 973 
Capital loss carryforward2,005 64,875 
Excess business interest expense45,188 22,275 
Net operating loss carryforward166,864 103,559 
Total deferred tax assets273,941 380,135 
Deferred tax liabilities:
Deductible goodwill and other intangibles(19,250)(8,169)
Right-of-use assets(8,227)(19,160)
Equity method investments(31,057)(27,435)
Other(11,381)(5,479)
Total deferred tax liabilities(69,915)(60,243)
Net deferred tax assets204,026 319,892 
Valuation allowance(207,372)(311,756)
Net deferred tax (liability) asset$(3,346)$8,136 
Deferred tax assets, net$763 $13,598 
Deferred tax liabilities, net(4,109)(5,462)
Net deferred tax (liability) asset$(3,346)$8,136 
As of December 31, 2025, the Company had federal net operating loss carryforwards of $602,913 and state net operating loss carryforwards of $688,239. As of December 31, 2024, the Company had federal net operating loss carryforwards of $344,508 and state net operating loss carryforwards of $71,248. There was no benefit or expense for income taxes recorded on net operating losses during the year ended December 31, 2025 or 2024 due to the valuation allowance. The Company has $39,319 of state capital loss carryovers as of December 31, 2025 that is available for carryforwards and will start to expire December 31, 2028. The Company’s federal net operating loss carryforwards generated in 2023 through 2025 of $278,310 will be limited to offsetting 80% of taxable income but do not expire. The remaining federal net operating loss carryforwards will expire in the tax years commencing in December 31, 2033 through December 31, 2038. The state net operating loss carryforwards will expire in tax years commencing in December 31, 2030.

The Company establishes a valuation allowance if, based on the weight of available evidence, it is more likely than not that some portion or all of the deferred tax assets will not be realized. Tax benefits of operating loss, capital loss, and tax credit carryforwards are evaluated on an ongoing basis, including a review of historical and projected future operating results, the eligible carryforward period, and other circumstances. The Company’s net operating losses are subject to annual limitations in accordance with Internal Revenue Code Section 382. Accordingly, the Company is limited to the amount of net operating loss that may be utilized in future taxable years depending on the Company’s actual taxable income. As of December 31, 2025, a valuation allowance in the amount of $207,372 has been recorded, as it is more likely than not that the Company will not be able to utilize tax benefits before they expire. The valuation allowance decreased by $104,384 during the year ended December 31, 2025, primarily due to realized losses in 2025 from loans receivable and investments, the utilization of capital loss carryforwards to offset gains from the sale of businesses in the current year, and the release of the valuation allowance established for tax attributes that no longer exist at December 31, 2025 that related to a foreign subsidiary that was liquidated in 2025. As of December 31, 2024, a valuation allowance in the amount of $311,756 has been recorded since it is more likely than not that the Company will not be able to utilize tax benefits before they expire. The Company’s net deferred tax assets at December 31, 2024 of $11,013 represent the amount of refund claims available from capital loss carrybacks of previously reported taxable capital gains in prior year tax returns. The valuation allowance increased by $207,439 during the year ended December 31, 2024, primarily due net operating losses, realized and unrealized losses on investments, and fair value adjustments for loans receivable in the current year.
As of December 31, 2025, the Company did not have any gross unrecognized tax benefits which would have an impact on the Company’s effective income tax rate, if recognized. A reconciliation of the amounts of gross unrecognized tax benefits (before federal impact of state items), excluding interest and penalties, was as follows:
Year Ended December 31,
20252024
Beginning balance$13,162 $14,819 
Additions for prior year tax positions4,177 23 
Reductions for prior year tax positions(6,461)— 
Reductions due to lapse in statutes of limitations(3,363)(1,680)
Ending balance$7,515 $13,162 

The Company files income tax returns in the U.S., various state and local jurisdictions, and certain other foreign jurisdictions. The Company is currently under audit by certain state and local and foreign tax authorities. The audits are in varying stages of completion. The Company evaluates its tax positions and establishes liabilities for uncertain tax positions that may be challenged by tax authorities. Uncertain tax positions are reviewed on an ongoing basis and are adjusted in light of changing facts and circumstances, including progress of tax audits, case law developments, and closing of statutes of limitations. Such adjustments are reflected in the provision for income taxes, as appropriate. The Company is currently open to audit under the statute of limitations by the Internal Revenue Service for the calendar years ended December 31, 2022 to 2025. At December 31, 2025, the Company intends to indefinitely reinvest foreign earnings and cash unless such repatriation results in no or minimal tax costs. It is not practicable to determine the amount of an unrecognized deferred tax liability for temporary differences related to investments in foreign subsidiaries.
As of December 31, 2025, the Company believes it is reasonably possible that its gross liabilities for unrecognized tax benefits may decrease by $1,838 within the next 12 months due to expiration of statute of limitations.
During the year ended December 31, 2025, the Company had accrued interest and penalties relating to uncertain tax positions of $3,820, which is included in income taxes payable. During the year ended December 31, 2025, the Company
recorded a release of $9,415, related to interest and penalties for uncertain tax positions primarily due to the lapse in statute of limitations.
On July 4, 2025, the “One Big Beautiful Bill Act” (the “Act”) was enacted into law. The Act includes changes to U.S. tax law that will be applicable to the Company beginning in fiscal year 2026. These changes include provisions allowing accelerated tax deductions for qualified property and research expenditures. The changes are not expected to have a material impact to the Company.