v3.26.1
Income Taxes
6 Months Ended
Jun. 30, 2026
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The Company’s effective tax rate for the three and six months ended June 30, 2026 and 2025 varies from the statutory U.S. federal income tax rate primarily due to the Company being designated as a REIT that is generally treated as a non-tax paying entity. During the three and six months ended June 30, 2026 and 2025, the effective tax rate was impacted by the blend of pre-tax book income and losses generated year over year by jurisdiction. During the six months ended June 30, 2026, a non-recurring $3.9 million discrete tax expense was recognized attributable to the establishment of a valuation allowance in the U.S.
The international tax framework (“Pillar Two”) created by the Organization for Economic Co-operation and Development (“OECD”) includes a global minimum tax of 15 percent. Legislation adopting these provisions has been enacted in certain jurisdictions where the Company operates and was effective starting in the Company's 2024 calendar year. The Company concluded that the legislation does not have a material impact on the Company’s income tax expense. On January 5, 2026, the OECD announced a comprehensive Side-by-Side safe harbor package (the “SBS Safe Harbor”) that, if enacted, would exempt U.S.-parented multinational companies from certain Top-Up Taxes under Pillar Two beginning January 1, 2026. While the SBS Safe Harbor is not yet enacted in any foreign jurisdiction where we operate, we expect that the SBS Safe Harbor may be adopted prior to the year ended December 31, 2026.
On July 4, 2025, the One Big Beautiful Bill Act (“OBBBA”) was enacted in the U.S. The OBBBA makes permanent certain key elements of the Tax Cuts and Jobs Act, including 100% bonus depreciation, domestic research cost expensing, and the business interest expense limitation. ASC 740 - Income Taxes, requires the tax effects of changes in tax rates and laws to be recognized in the period in which the legislation is enacted. Those effects, both current tax and deferred tax, are reported as part of continuing operations. The legislation was signed into law during the six months ended September 30, 2025. Certain provisions apply to tax years beginning after December 31, 2025, the estimated impact was included in continuing operations for the three and six months ended June 30, 2026 and was not material.