v3.26.1
Income Taxes
 6 Months Ended
Jun. 30, 2026
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The effective tax rate for the three months ended June 30, 2026 was 17.4%, compared with 19.0% for the three months ended June 30, 2025. The decrease in the quarterly effective tax rate primarily reflects favorable international tax planning initiatives and favorable return to provision adjustments.
At June 30, 2026, the Company had gross uncertain tax benefits of $243.3 million, of which $192.6 million, if recognized, would impact the effective tax rate.
The following is a reconciliation of the liability for uncertain tax positions (in millions):
Balance at December 31, 2025$229.3 
Additions for tax positions23.5 
Reductions for tax positions(9.5)
Balance at June 30, 2026$243.3 
The additions above primarily reflect the tax positions for foreign tax planning initiatives. The Company recognizes interest and penalties accrued related to uncertain tax positions in income tax expense. The amounts recognized in income tax expense for interest and penalties during the three and six months ended June 30, 2026 and 2025 were not significant.
The Organization for Economic Cooperation and Development’s (“OECD”) Pillar Two initiative set a 15% global minimum tax for certain multinationals, effective January 1, 2024, in most countries where the Company operates. In January 2026, new OECD guidance proposed a Side‑by‑Side (“SbS”) framework to limit Pillar Two taxes for U.S.-parented groups. Relief is contingent upon the implementation of the SbS framework within each respective jurisdiction's domestic legislation. For the six months ended June 30, 2026, the Company has recorded $12.5 million of top-up tax in its income tax expense, based on the currently enacted Pillar Two framework, in jurisdictions where the effective tax rate does not meet the 15% minimum threshold.