v3.25.0.1
INCOME TAXES (Tables)
12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
Schedule of Income before Income Tax, Domestic and Foreign
Income (loss) before income taxes for the years ended December 31, 2024, 2023 and 2022 consists of the following:
Year ended December 31,
($ in millions)202420232022
Ireland$(292)$144 $298 
United States115 (264)(429)
Other countries193 (971)(164)
Income (loss) before income taxes $16 $(1,091)$(295)
Schedule of (Benefit) Provision for Income Taxes
The components of income tax expense for the year ended December 31, 2024, 2023 and 2022 consists of the following:
 Year ended December 31,
($ in millions)202420232022
Current:
Ireland$7 $44 $42 
U.S. federal(3)(1)— 
U.S. state4 6 (1)
Other countries194 203 179 
Total current tax expense202 252 220 
Deferred:
Ireland$2 $1 $(7)
U.S. federal(200)— — 
U.S. state(47)— — 
Other countries(103)(133)(138)
Total deferred tax (benefit)(348)(132)(145)
Total income tax (benefit) expense$(146)$120 $75 
Schedule of (Benefit) Provision for Income Taxes
The reconciliation between the Irish statutory income tax rate, the trading income tax rate of our country of domicile, and our actual effective tax rate for the years ended December 31, 2024, 2023 and 2022 are as follows:
 Year ended December 31,
 202420232022
Irish corporation trading tax rate of
12.5 %(12.5)%(12.5)%
Depreciation on non-qualifying property and equipment8.9 %0.1 %(1.6)%
Effect of different statutory income tax rates in foreign jurisdictions226.0 %4.7 %(8.8)%
Non-deductible expenses230.5 %1.5 %9.8 %
Non-deductible expenses (non-taxable) Fox option expense (income)606.1 %3.6 %(3.9 %)
Non-taxable income(219.9)%(1.6)%(0.6)%
Recognition of deferred tax on internal asset transfers— %— %(16.5)%
Effect of changes in statutory income tax rates1.7 %0.1 %(0.8 %)
Change in valuation allowance(1444.5 %)12.1 %57.1 %
Under (over) provision in prior year(333.8 %)3.0 %3.2 %
Actual effective tax rate (912.5)%11.0 %25.4 %
Schedule of Components of Net Deferred Income Tax Asset (Liability)
The components of deferred tax assets (liabilities) were as follows as of December 31, 2024 and 2023:
 As of December 31,
($ in millions)20242023
Deferred tax assets
Property and equipment$39 $29 
Irish deferred amortization deductions65 34 
Share-based compensation44 63 
Net operating loss carryforwards850 881 
Other226 168 
Total deferred tax assets1,224 1,175 
Valuation allowance(878)(1,067)
Total deferred tax assets, net of valuation allowance346 108 
Deferred tax liabilities
Intangible assets(684)(886)
Total deferred tax liabilities(684)(886)
Net deferred tax liabilities$(338)$(778)
Summary of Valuation Allowance
The movement in the valuation allowance was comprised of the following as of December 31, 2024, 2023 and 2022:
 Year ended December 31,
($ in millions)202420232022
Balance Beginning of year$1,067 $1,069 $1,102 
Increase recognized in income tax expense80 172 83 
Decrease recognized in income tax expense(306)(39)(72)
Foreign currency translation adjustments(11)(56)(44)
Recognized in income tax expense - adjustment in relation to prior years48 — — 
Written off deferred tax assets— (79)— 
Net change in the valuation allowance(189)(2)(33)
Balance End of year$878 $1,067 $1,069 
Schedule of Unrecognized Tax Benefits Reconciliation
The following table presents a reconciliation of the total amounts of unrecognized tax benefits, excluding interest and penalties:
As of December 31,
($ in millions)202420232022
Unrecognized tax benefits at beginning of the year$129 $237 $188 
Increases for tax positions of prior years36 9 — 
Decreases for tax positions of prior years(2)(131)(1)
Increases for tax positions of the current year5 6 82 
Reductions to unrecognized tax benefits as a result of a lapse of the applicable statute of limitations(8)(3)(4)
Settlements(5)— (6)
Foreign currency translation adjustments(2)11 (22)
Unrecognized tax benefits at the end of the year$153 $129 $237