v3.25.0.1
Income Taxes (Tables)
 12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
Schedule of Income Before Income Taxes Attributable to Geographic Locations
Income before income taxes is attributable to the following geographic locations for the years ended December 31 (in millions):
202420232022
Domestic $147 $278 $334 
Foreign 828 846 495 
Income before income taxes
$975 $1,124 $829 
Schedule of Components of Tax Benefit (Expenses) for Income Taxes
The tax expenses for income taxes consisted of the following components for the years ended December 31 (in millions):
202420232022
Current:
Federal $1 $— $2 
State and local (3)— (1)
Foreign (189)(150)(83)
Subtotal
(191)(150)(82)
Deferred:
Federal — — (16)
State and local 2 — (5)
Foreign 28 (5)(21)
Subtotal
30 (5)(42)
Income tax expense
$(161)$(155)$(124)
Schedule of Income Tax Reconciliation
Income tax benefit (expenses) for the years ended December 31, 2024, 2023 and 2022 differed from the amounts computed by applying the U.S. federal income tax rate of 21% to pre-tax income as a result of the following for the years ended December 31 (in millions):
2024
2023 (1)
2022 (1)
Federal tax at statutory rate $(205)$(236)$(174)
State and local tax expense(1)— (6)
Foreign income tax rate differential (12)(14)(12)
Non-deductible expenses (10)(6)(6)
Stock-based compensation expense (8)(9)(8)
Change in valuation allowance(72)(32)(59)
Foreign financing activities(2)(4)(6)
Uncertain tax positions reserve 11 21 45 
Tax adjustments related to REIT130 132 107 
Change in deferred tax adjustments1 (3)— 
Effect of tax rate change on deferred tax assets— (2)(3)
Other, net 7 (2)(2)
Total income tax expense
$(161)$(155)$(124)
(1)The prior year amounts presented in the table above have been reclassified to conform with the current year presentation, The rate reconciliation item 'Deferred tax assets generated in current year not benefited' has been grouped with 'Change in valuation allowance'.
Schedule of Deferred Tax Assets and Liabilities
The types of temporary differences that give rise to significant portions of our deferred tax assets and liabilities are set out below as of December 31 (in millions):
20242023
Deferred tax assets:
Stock-based compensation expense $10 $9 
Net unrealized losses12 11 
Operating lease liabilities217 221 
Finance lease liabilities— 14 
Deferred revenue11 17 
Loss carryforwards and tax credits253 232 
Others, net25 7 
Gross deferred tax assets
528 511 
Valuation allowance (277)(221)
Total deferred tax assets, net 251 290 
Deferred tax liabilities:
Finance lease liabilities(13)— 
Property, plant and equipment(200)(253)
Right-of-use assets(220)(224)
Deferred income(5)(26)
Goodwill(17)(3)
Intangible assets (87)(116)
Total deferred tax liabilities
(542)(622)
Net deferred tax liabilities$(291)$(332)
Schedule of Changes in Valuation Allowance for Deferred Tax Assets
Changes in the valuation allowance for deferred tax assets for the years ended December 31 are as follows (in millions):
202420232022
Beginning balance $221 $167 $101 
Amounts from acquisitions
— 10 13 
Amounts recognized into income
6 (2)23 
Current increase57 44 37 
Impact of foreign currency exchange
(7)2 (7)
Ending balance $277 $221 $167 
Schedule of Net operating Loss Carryforwards
Our net operating loss carryforwards for federal, state and foreign tax purposes which expire, if not utilized, at various intervals from 2025, are outlined below (in millions):
Expiration DateFederalState
Foreign (1) (2)
Total
2025$1 $— $8 $9 
2026 to 20282 — 50 52 
2029 to 2031— — 26 26 
2032 to 2034— — 49 49 
2035 to 20373 — 20 23 
2038 to 2040— 4 55 59 
Thereafter239 92 570 901 
$245 $96 $778 $1,119 
(1)In certain jurisdictions, the net operating loss carryforwards can only be used to offset a percentage of taxable income in a given year.
(2)If certain substantial changes in the entity's ownership occur, there may be a limitation on the amount of the carryforwards that can be utilized.
Schedule of Reconciliation of Unrecognized Tax Benefits
The beginning and ending balances of our unrecognized tax benefits are reconciled below for the years ended December 31 (in millions):
202420232022
Beginning balance$70 $89 $148 
Gross increases related to prior year tax positions
— 3 1 
Gross decreases related to prior year tax positions
(12)(17)(43)
Gross increases related to current year tax positions
7 5 7 
Decreases resulting from expiration of statute of limitation
(7)(10)(12)
Decreases resulting from settlements
(1)— (12)
Ending balance$57 $70 $89