Annual report [Section 13 and 15(d), not S-K Item 405]

Income Taxes

v3.25.0.1
Income Taxes
12 Months Ended
Dec. 31, 2024
Income Taxes  
Income Taxes

(10)  Income Taxes

Income tax benefit (expense) consists of:

Years ended December 31,

 

    

2024

    

2023

    

2022

 

amounts in millions

 

Current:

Federal

$

42

 

32

 

78

State and local

 

6

 

1

 

(2)

Foreign

 

(58)

 

(41)

 

(24)

 

(10)

 

(8)

 

52

Deferred:

Federal

 

(1)

 

(12)

 

(171)

State and local

 

1

 

(1)

 

(9)

Foreign

 

(29)

 

22

 

330

 

(29)

 

9

 

150

Income tax benefit (expense)

$

(39)

 

1

 

202

The following table presents a summary of our domestic and foreign earnings (loss) from continuing operations before income taxes:

Years ended December 31,

 

    

2024

    

2023

    

2022

 

amounts in millions

 

Domestic

$

(468)

 

(299)

 

479

Foreign

 

444

 

274

 

228

Total

$

(24)

 

(25)

 

707

Expected income tax benefit (expense) differs from the amounts computed by applying the U.S. federal income tax rate of 21% for the years ended December 31, 2024, 2023 and 2022 as a result of the following:

Years ended December 31,

 

    

2024

    

2023

    

2022

 

amounts in millions

 

Computed expected tax benefit (expense)

$

5

 

5

 

(148)

State and local income taxes, net of federal income taxes

 

6

 

1

 

(9)

Foreign income taxes, net of foreign tax credit

15

3

22

Change in valuation allowance affecting tax expense

 

(2)

 

(5)

 

338

Stock-based compensation

16

6

11

Non-deductible executive compensation

(11)

(3)

(6)

Non-taxable gain / (non-deductible loss)

(49)

(3)

3

Foreign currency adjustments

25

Non-deductible interest

(7)

(6)

(4)

Capitalized transaction costs

(7)

(3)

(2)

Intergroup interest

(14)

4

Other, net

 

(5)

 

(5)

 

(7)

Income tax benefit (expense)

$

(39)

 

1

 

202

For the year ended December 31, 2024, the Company recognized income tax expense instead of a tax benefit at the expected federal rate of 21% primarily due to certain losses that are not deductible for tax purposes and non-deductible executive compensation, partially offset by tax benefits related to stock-based compensation and earnings in foreign jurisdictions taxed at rates lower than the 21% U.S. federal rate.

For the year ended December 31, 2023, the Company recognized a tax benefit less than the expected federal rate of 21% primarily due to intergroup interest losses that are not deductible for tax purposes and certain other non-deductible expenses, partially offset by a tax benefit related to foreign currency adjustments on certain U.K. deferred tax assets.

For the year ended December 31, 2022, the Company recognized a tax benefit instead of a tax expense at the expected federal rate of 21% primarily due to a decrease in our valuation allowance and earnings in foreign jurisdictions taxed at rates lower than the 21% U.S. federal rate.

The tax effects of temporary differences that give rise to significant portions of the deferred income tax assets and deferred income tax liabilities are presented below:

December 31,

 

    

2024

    

2023

 

amounts in millions

 

Deferred tax assets:

Tax loss and credit carryforwards

$

628

 

687

Other accrued liabilities

 

14

 

15

Investments

103

123

Intangible assets

12

2

Accrued stock compensation

 

7

10

Discount on debt

86

22

Deferred tax assets

 

850

 

859

Valuation allowance

 

(10)

 

(8)

Net deferred tax assets

 

840

 

851

Deferred tax liabilities:

Fixed assets

80

79

Deferred tax liabilities

 

80

 

79

Net deferred tax assets (liabilities)

$

760

 

772

During the year ended December 31, 2024, there was a $2 million increase in the Company’s valuation allowance.

At December 31, 2024, the Company had a deferred tax asset of $628 million for federal, state and foreign net operating losses (“NOLs”) and interest expense carryforwards. Of this amount, the Company has $11 million of federal NOLs, $2 million of state NOLs, $30 million of federal interest expense carryforwards, $274 million of foreign NOLs and $311 million of foreign interest expense carryforwards that may be carried forward indefinitely. These losses and interest carryforwards are expected to be utilized prior to expiration, except for $10 million, which, based on current projections, will not be utilized in the future and are subject to a valuation allowance.

As of December 31, 2024, the Company had not recorded tax reserves related to unrecognized tax benefits for uncertain tax positions.

As of December 31, 2024, the Company’s tax years prior to 2021 are closed for federal income tax purposes. The Company’s 2021 tax year is not under audit, but remains open until the statute of limitations lapses on October 15, 2025. The IRS has completed its examination of the Company’s 2022 tax year.  However, 2022 remains open until the statute of limitations lapses on October 15, 2026. The Company’s 2023 and 2024 tax years are currently under examination as part of the IRS Compliance Assurance Process program. Various states are currently examining the Company’s prior years’ state income tax returns. We do not expect the ultimate disposition of these audits to have a material adverse effect on our financial position or results of operations.