v3.26.3
Income Taxes
9 Months Ended
Sep. 30, 2026
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
On July 4, 2025, the One Big Beautiful Bill Act (the "OBBBA") was enacted in the United States, which extended and modified certain provisions of the 2017 Tax Cuts and Jobs Act (the "TCJA"). The provisions of the OBBBA did not have a material impact on the Company's operating results, financial position or cash flows for the three and nine months ended September 30, 2026.

The Company's effective tax rate for the three months ended September 30, 2026 and 2025 was 24.4% and 21.8%, respectively, and 23.3% and 22.7% for the nine months ended September 30, 2026 and 2025, respectively. The effective tax rate for the nine months ended September 30, 2026 included a discrete tax benefit of $34 million in the first quarter of 2026 primarily related to the resolution of a U.S. tax audit. The effective tax rates for the three and nine months ended September 30, 2025 benefited from a discrete tax benefit in the third quarter of 2025 of $43 million related to the estimated U.S. federal tax liability for 2024, partially offset by a $16 million discrete tax expense related primarily to the resolution of a foreign tax audit. Additionally, the effective tax rate for the nine months ended September 30, 2025 included a discrete tax benefit of $21 million in the first quarter of 2025 related to the reversal of a valuation allowance on net operating loss carryforwards. The effective tax rates for 2026 and 2025 also included excess tax benefits from stock-based compensation of $1 million and $2 million for the three months ended September 30, 2026 and 2025, respectively, and $5 million and $7 million for the nine months ended September 30, 2026 and 2025, respectively.

The Company and its subsidiaries file tax returns in the U.S. and various state, local and foreign jurisdictions. These tax returns are routinely audited by the tax authorities in these jurisdictions, including the U.S. Internal Revenue Service (the "IRS"), His Majesty's Revenue and Customs, German Fiscal Authority, French Fiscal Authority, and Australian Tax Office, and a number of these audits are currently ongoing, which may change the amount of the unrecognized tax benefits in future periods. The Company has recorded its best estimate of the potential exposure for these issues.

In September 2026, the Company received a Notice of Deficiency ("NOD") from the IRS related to the 2018 through 2021 tax years. The NOD assessed $23 million of additional income taxes, plus interest and penalties, in connection with a 2021 capital loss resulting from the liquidation of a legal entity. The NOD also disallowed $47 million of income tax refund claims related to the capital loss and certain amended tax returns. For tax years subsequent to 2021, additional income taxes associated with these matters total $148 million. The Company intends to petition the United States Tax Court to challenge the NOD. Although the outcome of this matter cannot be predicted with certainty, the Company believes it will be successful in defending its position.