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Income Taxes
 9 Months Ended
Sep. 30, 2021
Income Tax Disclosure [Abstract]  
Income Taxes
12. INCOME TAXES
INCOME TAX EXPENSE
Income Tax Rate Reconciliation
Three Months Ended September 30,Nine Months Ended September 30,
2021202020212020
Tax provision at U.S. federal statutory rate$122 $111 $419 $308 
Tax-exempt interest(10)(12)(31)(36)
Increase in deferred tax valuation allowance (1)6 6 19 
Sale of business— (8)(5)(8)
Earnings on corporate owned life insurance(5)(6)(16)(3)
Carryback benefit— (5)— (5)
Tax credits(8)(4)(9)(4)
Tax law change1 (6)(6)(6)
Other 2 (3)2 3 
Provision for income taxes$101 $73 $360 $268 
UNCERTAIN TAX POSITIONS
Rollforward of Unrecognized Tax Benefits
 Three Months Ended September 30,Nine Months Ended September 30,
 2021202020212020
Balance, beginning of period$15 $14 $15 $14 
Gross increases - tax positions in prior period— — — — 
Gross decreases - tax positions in prior period— — — — 
Gross increases - tax positions in current period5 1 5 1 
Lapse of statute of limitations(5)— (5)— 
Balance, end of period$15 $15 $15 $15 
The entire amount of unrecognized tax benefits, if recognized, would affect the effective tax rate in the period of the release. The Company recognized $5 of its previously unrecognized tax benefits associated with dividends from segregated asset accounts of the life and annuity business sold in 2018. This liability was subject to a tax indemnification agreement and a corresponding receivable included in other assets has been taken down upon lapse of the statute of limitations.
OTHER TAX MATTERS
On June 10, 2021, the United Kingdom enacted Finance Bill 2021, which included an increase in the corporate tax rate from 19% to 25%, effective April 1, 2023. In the nine months ended September 30, 2021, the Company recorded a tax benefit of $6, which reflects the estimated benefit of the change in tax rate on the net deferred tax assets of its U.K. subsidiaries.
On March 27, 2020, as part of the business stimulus package in response to the COVID-19 pandemic, the U.S. government enacted the Coronavirus Aid, Relief, and Economic Security ("CARES") Act. The CARES Act established new tax provisions including, but not limited to: (1) five-year carryback of net operating losses ("NOLs") generated in 2018, 2019 and 2020; (2) accelerated refund of alternative minimum tax ("AMT") credit carryforwards; and (3) retroactive changes to allow accelerated depreciation for certain depreciable property.
For the period ending September 30, 2020 the Company recorded a tax benefit of $11 related to the carryback of losses from the Navigators Group 2019 pre-acquisition tax return to recover taxes paid in prior years at the previous statutory tax rate of 35%, of which $5 related to the existing insurance company carryback provision and $6 was due to the non-insurance carryback provision of the CARES Act.
For the nine months ended September 30, 2021 and 2020, the Company recorded a tax benefit of $5 and $8 related to the excess tax basis over GAAP basis on the sale of the Continental Europe Operations. For discussion of this transaction, refer to Note 17 - Business Disposition.
As of September 30, 2021, the Company has foreign net operating losses of $23 for which a valuation allowance of $4 has been established. While the foreign net operating losses ("NOLs") do not expire, this assessment reflects uncertainty in the Company's ability to generate sufficient taxable income in the near term in those specific jurisdictions.
Management has assessed the need for a valuation allowance against its deferred tax assets based on tax character and jurisdiction. In making the assessment, management considered future taxable temporary difference reversals, future taxable income exclusive of reversing temporary differences and carryovers, taxable income in open carry back years and other
tax planning strategies which management views as prudent and feasible.
The federal income tax audits for the Company have been completed through 2013, and the Company is not currently under federal income tax examination for any open years. The statute of limitations is closed through the 2017 tax year with the exception of NOL carryforwards utilized in open tax years. Management believes that adequate provision has been made in the Company's Condensed Consolidated Financial Statements for any potential adjustments that may result from tax examinations and other tax-related matters for all open tax years.