Income Taxes (Tables)

12 Months Ended

Dec. 31, 2025

Schedule of Income Before Income Tax Provision (Benefit)

Our income from continuing operations before income taxes was subject to taxes in the following jurisdictions for the following periods (in millions):


	Years Ended December 31,
	2025		2024		2023
United States	$	17.6	$	42.0	$	65.8
Foreign	70.0		69.5		63.7
Total	$	87.6	$	111.5	$	129.5

Schedule of Expense (Benefit) for Income Taxes

The provision (benefit) for income taxes allocated to continuing operations is comprised of (in millions):


	Years Ended December 31,
	2025		2024		2023
Current tax provision:
Federal	$	13.7	$	18.9	$	29.0
State	3.3		2.5		3.8
Foreign	12.9		8.6		7.0
	29.9		30.0		39.8
Deferred tax provision (benefit):
Federal	17.6		(10.9)		(12.5)
State	3.5		0.7		(0.2)
Foreign	(2.2)		(1.7)		2.9
	18.9		(11.9)		(9.8)
Income tax provision (benefit)	$	48.8	$	18.1	$	30.0

Schedule of Components of Deferred Tax Assets and Liabilities

Significant components of our deferred tax assets and liabilities as of December 31, 2025 and 2024 are as follows (in millions):


		December 31,
		2025		2024
Deferred tax assets:
Tax loss and interest expense carryforwards		$	109.1	$	50.1
Tax credit carryforwards		87.7		65.6
Lease liabilities		403.8		412.0
Deemed landlord financing		326.7		297.2


Other deferred tax assets		113.7		108.5
Total deferred tax assets		1,041.0		933.4
Valuation allowance for deferred tax assets		(143.4)		(31.3)
Deferred tax assets, net of valuation allowance		897.6		902.1
Deferred tax liabilities:
Basis difference related to fixed assets		(238.9)		(235.7)
Basis difference related to intangible assets with an indefinite life		(185.9)		(241.9)
Lease right-of-use assets		(359.1)		(371.3)
Other deferred tax liabilities		(6.3)		(6.8)
Total deferred tax liabilities		(790.2)		(855.7)
Net deferred tax assets (liabilities) are shown on the accompanying consolidated balance sheets as follows:
	Balance Sheet Location
Non-current deferred tax assets	Other assets, net	109.2		48.6
Non-current deferred tax liabilities	Other long-term liabilities	(1.8)		(2.2)
Deferred tax assets, net		$	107.4	$	46.4

Schedule of Credit Carryforward Expiry

As of December 31, 2025, we had U.S. federal and state income tax credit carryforwards of $73.5 million and $35.9 million, respectively, which will expire if unused at various dates beginning on December 31, 2028. Such carryforwards expire as follows (in millions):


U.S. foreign tax credit	$	3.5	2028-2035
U.S. business tax credits	$	70.0	2037-2045
State business tax credits - indefinite lived	$	27.9	Do not expire
State business tax credits - definite lived	$	8.0	2032-2048

Schedule of Net Operating Losses Expiry

As of December 31, 2025, we had U.S. federal net operating loss (“NOLs”), capital loss, and interest expense carryforwards of $65.9 million, $352.1 million and $19.8 million, respectively. Such carryforwards expire as follows (in millions):


U.S. net operating loss carryforwards - definite lived	$	11.9	2028-2035
U.S. capital loss carryforwards - definite lived	$	352.1	2030
U.S. interest expense carryforwards - indefinite lived	$	19.8	Do not expire
U.S. net operating loss carryforwards - indefinite lived	$	54.0	Do not expire

Schedule of Reconciliation of Effective Tax Rate on Income or Loss and Statutory Tax Rate

A reconciliation of the effective tax rate on our 2025 income from continuing operations and the U.S. federal statutory tax rate is as follows (dollar amounts in millions):


	Year Ended December 31, 2025
	Dollars		Percentages
Pre-tax income	$	87.6

U.S. federal statutory income tax rate	18.4		21.0	%
Domestic federal
Tax credits
Research and development credits	(1.7)		(1.9)	%
Nontaxable and nondeductible items
Nondeductible compensation	5.5		6.3	%
Other nontaxable and nondeductible items	0.4		0.5	%
Cross-border tax laws
Global intangible low-taxed income, net of foreign tax credit	2.5		2.9	%
Foreign-derived intangible income deduction	(0.4)		(0.5)	%
Other cross-border tax laws	0.2		0.2	%
Changes in valuation allowances	24.0		27.4	%
Other adjustments	(0.8)		(0.9)	%

Domestic state and local income taxes, net of federal effect (1)	5.3		6.0	%

Foreign tax effects
China
Statutory income tax rate differential	1.8		2.1	%
Income excluded from corporate income tax	(10.5)		(12.0)	%
Hong Kong
Global minimum tax	3.7		4.2	%
Japan
Statutory income tax rate differential	1.0		1.1	%
Other	(0.2)		(0.2)	%
Other foreign jurisdictions	0.2		0.2	%

Worldwide changes in unrecognized tax benefits	(0.6)		(0.7)	%
Income tax provision and effective tax rate	$	48.8	55.7	%

(1) The majority (greater than 50%) of the income tax effect within this category was from the following state and local jurisdictions: California, Illinois, New Jersey, New York, Pennsylvania, and Texas.

A reconciliation of the effective tax rate on our 2024 and 2023 income from continuing operations and the U.S. federal statutory tax rate is as follows:


	Years ended December 31,
	2024		2023
Statutory U.S. tax rate	21.0	%	21.0	%
State income taxes, net of U.S. tax benefit	2.3	%	2.2	%
Foreign income taxed at other than U.S. statutory rate	(7.0)	%	(3.6)	%
Federal tax credits	(4.7)	%	(3.6)	%
Other non-deductible expenses	1.3	%	0.8	%
Non-deductible compensation	4.0	%	3.7	%
U.S. Foreign tax inclusion	1.4	%	1.4	%
Foreign derived intangible income deduction	(2.7)	%	(2.7)	%

Impact of uncertain tax positions	0.8	%	1.5	%
Change in deferred tax valuation allowance	(0.1)	%	—	%

Other	(0.1)	%	2.5	%
Effective tax rate	16.2	%	23.2	%

Schedule of Reconciliation of Unrecognized Tax Benefits

A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows (in millions):


	2025		2024		2023
Balance at January 1	$	27.7	$	29.3	$	26.2
Additions based on tax positions related to the current year	0.7		2.1		1.8
Additions for tax positions of prior years	—		—		2.0
Reductions for tax positions of prior years	(1.3)		(0.8)		—
Settlement of tax audits	(6.1)		(1.1)		—
Current year dispositions	(2.2)		—		—
Reductions due to lapsed statute of limitations	(0.4)		(1.8)		(0.7)
Balance at December 31	$	18.4	$	27.7	$	29.3

Schedule of Major Jurisdictions No Longer Subject to Income Tax Examinations by Tax Authorities

We or one of our subsidiaries file income tax returns in the U.S. federal jurisdiction and various U.S. states and foreign jurisdictions. We are generally no longer subject to income tax examinations by tax authorities in our major jurisdictions as follows:


Major Tax Jurisdiction						Years No Longer Subject to Audit
U.S. Federal						2009 and prior


Japan						2019 and prior
South Korea						2021 and prior
United Kingdom						2020 and prior

Schedule of Income Taxes Paid, Net of Refunds Received

Income taxes paid, net of refunds received, during 2025 by jurisdiction were (in millions):


	Year Ended December 31,
	2025
U.S. federal	$	1.0
U.S. state and local
Texas	1.4
Other	7.5
Foreign
Canada	1.4
China	2.5
Japan	5.0
Other	4.1
Total income taxes paid, net	$	22.9