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Income Taxes
9 Months Ended
Sep. 30, 2024
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
For the three and nine months ended September 30, 2024, income tax expense was $19.9 million on income from operations before income taxes of $66.3 million, and $54.4 million on income from operations before income taxes of
$126.0 million, respectively, representing an effective tax rate of 30% and 43%, respectively. The effective tax rate for the nine months ended September 30, 2024 was impacted by the $68.0 million nondeductible goodwill impairment charge at AMCNI. Inclusive of the nondeductible goodwill impairment charge, items resulting in variances from the federal statutory rate of 21% for the three and nine months ended September 30, 2024 primarily consisted of state and local income tax expense, tax expense from foreign operations, tax expense for an increase in the valuation allowance for foreign taxes and tax expense related to non-deductible compensation.
For the three and nine months ended September 30, 2023, income tax expense was $23.7 million on income from operations before income taxes of $91.6 million, and $82.7 million on income from operations before income taxes of $324.0 million, respectively, representing an effective tax rate of 26% for both periods. The items resulting in variances from the federal statutory rate of 21% for the three and nine months ended September 30, 2023 primarily consisted of state and local income tax expense and tax expense related to non-deductible compensation.
At September 30, 2024, the Company had foreign tax credit carry forwards of $55.2 million, expiring on various dates from 2024 through 2034. These carryforwards have been reduced to zero by a valuation allowance of $55.2 million as it is more likely than not that these carry forwards will not be realized.
During the second quarter of 2024, $28.6 million of cash and cash equivalents, previously held by foreign subsidiaries, was repatriated to the United States. Our consolidated cash and cash equivalents balance of $816.4 million, as of September 30, 2024, included $142.9 million held by foreign subsidiaries. Of this amount, approximately $35.0 million is expected to be repatriated to the United States with the remaining amount continuing to be reinvested in foreign operations. Tax expense related to the repatriated amount, as well as the expected remaining repatriation amount, has been accrued and we do not expect to incur any significant, additional taxes related to the remaining balance.
In December 2021, the Organization for Economic Co-operation and Development (OECD) released the Pillar Two Model Rules, which aim to reform international corporate taxation rules, including the implementation of a global minimum tax rate. The Company began the phased implementation of the Pillar Two Model Rules in the first quarter of 2024 and as of September 30, 2024, the Pillar Two minimum tax requirement is not expected to have a material impact upon the Company's results of operations or financial position for the year ending December 31, 2024.