v3.26.1
Income Taxes
 6 Months Ended
Jun. 30, 2026
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The Company’s income tax provision and effective income tax rate were as follows:
Three Months Ended
June 30,		Six Months Ended
June 30,
(In millions)2026202520262025
Components of income tax provision (benefit):
Current:
Federal$160 $279 $159 $405 
State33 70 76 106 
Foreign75 75 115 140 
268 424 350 651 
Deferred:
Federal(89)(126)82 (140)
State(11)(17)(2)(21)
Foreign(12)(35)(250)(54)
(112)(178)(170)(215)
Income tax provision$156 $246 $180 $436 
Effective income tax rate20.2 %19.0 %13.2 %18.6 %
The income tax provision as a percentage of income before income taxes and income (loss) from investments in unconsolidated affiliates was 20.2% and 19.0% for the three months ended June 30, 2026 and 2025, respectively, and 13.2% and 18.6% for the six months ended June 30, 2026 and 2025, respectively. The effective income tax rate for the six months ended June 30, 2026 included the impact of a $293 million benefit related to the release of a valuation allowance against certain foreign net operating loss carryforwards that were determined to be realizable during the first quarter of 2026. The Company monitors the realizability of deferred tax assets, taking into account all relevant factors, at each reporting period. This release was driven by a reevaluation of cumulative and future projected taxable income as a result of cross-border funding activities. This benefit was partially offset by a $39 million increase in U.S. federal unrecognized tax benefits for tax positions taken in prior years, $35 million in discrete tax expense from share-based awards and a $39 million increase in various other foreign valuation allowances during the first quarter of 2026. The net impact of these items resulted in a lower effective income tax rate compared to the statutory income tax rate. The effective income tax rate for the first six months ended June 30, 2025 included discrete tax benefits from share-based awards, resulting in a lower effective income tax rate compared to the statutory income tax rate.
Pursuant to provisions under the Inflation Reduction Act, the Company has purchased transferable federal tax credits from various counterparties. Such federal tax credits were purchased at negotiated discounts, resulting in an income tax benefit recorded for each of the six months ended June 30, 2026 and 2025. Receivables associated with transferable federal tax credits are recorded within prepaid expenses and other current assets, and amounts owed to counterparties for the purchased credits are recorded within accounts payable and other current liabilities within the consolidated balance sheets.
The Company’s potential liability for unrecognized tax benefits before interest and penalties was approximately $137 million and $97 million at June 30, 2026 and December 31, 2025, respectively. The Company believes it is reasonably possible that the liability for unrecognized tax benefits may decrease by up to $3 million over the next 12 months as a result of possible closure of tax audits, audit settlements, and the lapse of the statutes of limitations in various jurisdictions.
As of June 30, 2026, the Company’s U.S. federal income tax returns for 2019 and 2025, and tax returns in certain states and foreign jurisdictions for 2017 through 2025, remain subject to examination by taxing authorities.