17.INCOME TAXES

The Company evaluated the various provisions of the Tax Reform Act, including, the global intangible low-taxed income (“GILTI”) and the foreign derived intangible income provisions. The Company will treat any U.S. tax on foreign earnings under GILTI as a current period expense when incurred.

Consolidated retained earnings at December 31, 2024 included undistributed after-tax earnings from certain non-U.S. subsidiaries that were not indefinitely reinvested. At December 31, 2024, the Company had a deferred tax liability of $10.7 million for the estimated taxes associated with the repatriation of these earnings. Undistributed earnings of approximately $218.5 million in foreign subsidiaries were indefinitely reinvested in foreign operations. Quantification of the deferred tax liability, if any, associated with indefinitely reinvested earnings was not practicable.

The domestic and foreign components of the Company’s income before provision for income taxes are as follows:

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*After intercompany royalties, management fees and interest charges from the Company’s domestic to foreign entities of $108.4 million, $101.4 million and $85.0 million for the years ended December 31, 2024, 2023 and 2022, respectively.

Components of the provision for income taxes are as follows:

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A reconciliation of the total provision for income taxes after applying the U.S. federal statutory rate of 21% to income before provision for income taxes to the reported provision for income taxes are as follows for the years ended:

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Major components of the Company’s deferred tax assets (liabilities) at December 31, 2024 and 2023 are presented in the table below. Certain amounts as of December 31, 2023 have been reclassified to conform to presentation as of December 31, 2024.

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During the years ended December 31, 2024, 2023 and 2022, the Company established full valuation allowances against certain deferred tax assets from cumulative net operating losses incurred by certain foreign subsidiaries of the Company as well as state income tax related to cumulative net operating losses incurred by certain U.S. subsidiaries. The effect of the valuation allowances and the subsequent related impact on the Company’s overall tax rate was to increase the Company’s provision for income taxes by $8.6 million, $0.2 million and $2.7 million for the years ended December 31, 2024, 2023 and 2022, respectively. At December 31, 2024, the Company had net states operating loss carryforwards of approximately $58.5 million and net foreign operating loss carryforwards of approximately $109.0 million. Of these amounts, $65.4 million of net foreign operating loss carryforwards may be carried forward indefinitely. The remaining $102.1 million of net states and foreign operating loss carryforwards will begin to expire in 2025.

The following is a roll-forward of the Company’s total gross unrecognized tax benefits, not including interest and penalties, for the years ended December 31, 2024, 2023 and 2022:

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The Company recognizes accrued interest and penalties related to unrecognized tax benefits in the provision for income taxes in the Company’s consolidated financial statements. As of December 31, 2024, the Company had accrued approximately $0.7 million in interest and penalties related to unrecognized tax benefits. If the Company were to prevail on all uncertain tax positions, it would not have a significant impact on the Company’s effective tax rate.

It is expected that any change in the amount of unrecognized tax benefit change within the next 12 months will not be significant.

The Company is subject to U.S. federal income tax as well as to income tax in multiple state and foreign jurisdictions.

The Company is in various stages of examination with certain states and certain foreign jurisdictions. The Company’s 2021 through 2024 U.S. federal income tax returns are subject to examination by the IRS. The Company’s state income tax returns are subject to examination for the 2020 through 2024 tax years. The United Kingdom and Ireland income tax returns are subject to examination for the 2020 through 2024 tax years.