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Income Taxes
 9 Months Ended
Sep. 30, 2026
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The effective tax rate for the three months ended September 30, 2026 was 18.3%, compared with 17.1% for the three months ended September 30, 2025. The lower effective tax rate in the third quarter of 2025 primarily reflects the remeasurement of deferred tax liabilities following the enactment of a lower corporate tax rate in Germany.
At September 30, 2026, the Company had gross uncertain tax benefits of $271.8 million, of which $219.9 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 positions52.8 
Reductions for tax positions(10.3)
Balance at September 30, 2026$271.8 
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 nine months ended September 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. As of September 30, 2026, the SbS regime had not been enacted in any significant jurisdictions, as a result the Company is accruing for all Pillar 2 tax exposures, including QDMTT, IIR, and UTPR. For the nine months ended September 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. The Company continues to monitor global legislative developments and will adjust financial reporting upon formal enactment in relevant jurisdictions.