v3.26.1
Income Taxes
6 Months Ended
Jun. 30, 2026
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
On April 15, 2026, the Predecessor completed its spin-off from Madison Industries as part of the Organizational Transactions. Prior to the spin, the Predecessor was included in the consolidated federal income tax returns of Madison Industries International Holdings, LLC ("MIH") and deferred tax assets and liabilities were calculated under a carve-out methodology. As a result of the spin-off, the Predecessor remeasured certain tax attributes and recorded a $41.1 reduction to deferred tax assets related to disallowed interest expense carryforwards. Because this adjustment arose from the allocation of tax attributes in connection with the spin-off and represented a transaction with the owners, the impact was recorded as an adjustment to additional paid-in capital within shareholders' equity, rather than through income tax expense.
Subsequent to June 30, 2026, MIH divested a group of subsidiaries and expects to fully utilize the interest expenses limitation carryforwards from prior years in its 2026 tax return. As this transaction had not occurred as of the balance sheet date, the Company's allocation of the MIH deferred tax assets for the interest expenses limitation carryforward does not reflect the sale. Further adjustments will be recognized to the Company's deferred tax assets in the period in which the transaction is completed.
The Company's effective income tax rate was 36.5% and 37.5% for the three months ended June 30, 2026 and 2025, respectively, and 33.8% and 30.4%, for the six months ended June 30, 2026 and 2025, respectively. The decrease in the effective tax rate for the three months ended June 30, 2026 was driven by lower overall state tax impacts, primarily discrete items recorded in the second quarter of 2025; the decrease is partially offset by discrete write-offs in the second quarter of 2026 for executive compensation that is no longer deductible for tax purposes after the Company became a public business entity. The increase in the effective tax rate for the six months ended June 30, 2026 is primarily due to discrete write-offs in the second quarter of 2026 for executive compensation that is no longer deductible for tax purposes.
As of June 30, 2026, tax years 2021 and later remain open to audit for the U.S. federal jurisdiction and tax years 2019 and later remain open to audit in U.S. state jurisdictions. Tax years 2018 and later remain open to audit in foreign locations.
The Organization for Economic Co-operation and Development (“OECD”) issued Pillar Two model rules for a global minimum tax of 15% effective January 1, 2024. While the United States has not adopted Pillar Two, other countries in which the Company operates have enacted such legislation or are considering implementation. Given our limited operations in low-tax jurisdictions, Pillar Two has not materially increased our global tax costs. On January 5, 2026, the
OECD released a comprehensive package for a “side-by-side arrangement” with respect to Pillar Two. Notably, once adopted, this new guidance will prevent other countries from imposing tax on the U.S. profits of American companies. We will continue to monitor U.S. and international legislative developments, including further announcements on the side-by-side package, to assess any potential impacts on our operations. During the six months ended June 30, 2026, we have not accrued any tax expenses in connection with the incorporation of the Pillar Two model rules.