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Income Taxes | 12 Months Ended
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Dec. 31, 2024
Income Tax Disclosure [Abstract] |
Income Taxes | Arch Capital is incorporated under the laws of Bermuda and, under Bermuda law in effect as of December 31, 2024, is not obligated to pay taxes on income or capital gains in Bermuda. Upon its formation in 2000, the Company received a written undertaking from the Minister of Finance in Bermuda under the Exempted Undertakings Tax Protection Act 1966 assuring that, in the event that any legislation is enacted in Bermuda imposing any tax computed on profits, income, gain or appreciation on any capital asset, or any tax in the nature of estate duty or inheritance tax, such tax will not be applicable to Arch Capital or any of its operations until March 31, 2035. However, on December 27, 2023, the Government of Bermuda enacted the Bermuda CIT Act, which is effective for tax years beginning on or after January 1, 2025. Once in effect, the new corporate income tax regime in Bermuda is expected to supersede the Minister of Finance’s assurance, and the Company will become subject to taxes in Bermuda before March 31, 2035. The Bermuda CIT Act will apply a 15% corporate income tax to certain Bermuda constituent entities of multi-national groups in fiscal years beginning on or after January 1, 2025. The Company expects to incur and pay increased taxes in Bermuda beginning in 2025. The Bermuda CIT Act, together with the widespread adoption of the OECD Pillar II minimum tax proposal, is expected to result in a minimum effective tax rate of 15% in most jurisdictions in which the Company operates. Arch Capital has subsidiaries and branches that operate in various jurisdictions around the world that are subject to tax in the jurisdictions in which they operate. The significant jurisdictions in which Arch Capital’s subsidiaries and branches are subject to tax are the United States, United Kingdom, Ireland, Switzerland, Australia, Canada, and Gibraltar. The components of income taxes attributable to operations were as follows:
| Year Ended December 31,
| 2024 |  | 2023 |  | 2022
Current expense (benefit): |  |  |  |  |
United States | $ | 332 |  |  | $ | 251 |  |  | $ | 195 |
Non-U.S. | 65 |  |  | 37 |  |  | 6 |
| 397 |  |  | 288 |  |  | 201 |
Deferred expense (benefit): |  |  |  |  |
United States | (21) |  |  | (20) |  |  | (96) |
Non-U.S. | (14) |  |  | (1,141) |  |  | (25) |
| (35) |  |  | (1,161) |  |  | (121) |
Income tax expense (benefit) | $ | 362 |  |  | $ | (873) |  |  | $ | 80 |
The Company’s income or loss before income taxes was earned in the following jurisdictions:
| Year Ended December 31,
| 2024 |  | 2023 |  | 2022
Income (Loss) Before Income Taxes: |  |
Bermuda | $ | 2,611 |  |  | $ | 2,099 |  |  | $ | 986 |
United States | 1,438 |  |  | 1,239 |  |  | 401 |
Other | 625 |  |  | 232 |  |  | 175 |
Total | $ | 4,674 |  |  | $ | 3,570 |  |  | $ | 1,562 |
The expected tax provision computed on pre-tax income or loss at the weighted average tax rate has been calculated as the sum of the pre-tax income in each jurisdiction multiplied by that jurisdiction’s applicable statutory tax rate. The 2024 applicable statutory tax rates by jurisdiction were as follows: Bermuda (0.0%), United States (21.0%), United Kingdom (25.0%), Ireland (12.5%), Switzerland (19.6%), Australia (30.0%), Canada (26.4%) and Gibraltar (13.8%). A reconciliation of the difference between the provision for income taxes and the expected tax provision at the weighted average tax rate follows:
| Year Ended December 31,
| 2024 |  | 2023 |  | 2022
Expected income tax expense (benefit) computed on pre-tax income at weighted average income tax rate | $ | 424 |  |  | $ | 300 |  |  | $ | 110 |
Addition (reduction) in income tax expense (benefit) resulting from: |  |  |  |  |
Sale of subsidiaries/Bargain purchase option | (45) |  |  | — |  |  | — |
Investment income | (39) |  |  | (14) |  |  | (13) |
Change in tax rate | 12 |  |  | (1,179) |  |  | (5) |
Share based compensation | (11) |  |  | (13) |  |  | (9) |
Tax credits | (5) |  |  | (3) |  |  | (10) |
Base eroding tax/Alternative minimum tax | 5 |  |  | 9 |  |  | 8 |
State taxes, net of U.S. federal tax benefit | 4 |  |  | 6 |  |  | 11 |
Change in valuation allowance | 3 |  |  | 4 |  |  | (23) |
Uncertain tax position | 3 |  |  | — |  |  | — |
Dividend withholding taxes | 3 |  |  | 9 |  |  | 11 |
Other | 8 |  |  | 8 |  |  | — |
Income tax expense (benefit) | $ | 362 |  |  | $ | (873) |  |  | $ | 80 |
The effect of a change in tax laws or rates on deferred income tax assets and liabilities is recognized in income in the period in which such change is enacted. Deferred income tax assets and liabilities reflect temporary differences based on enacted tax rates between the carrying amounts of assets and liabilities for financial reporting and income tax purposes. Significant components of the Company’s deferred income tax assets and liabilities were as follows:
| December 31,
| 2024 |  | 2023
Deferred income tax assets: |  |  |
Net operating loss | $ | 77 |  |  | $ | 93 |
Discounting of net loss reserves | 203 |  |  | 219 |
Net unearned premium reserve | 190 |  |  | 133 |
Compensation liabilities | 75 |  |  | 64 |
Foreign tax credit carryforward | 22 |  |  | 16 |
Goodwill and intangible assets | 1,034 |  |  | 1,020 |
Bad debt reserves | 15 |  |  | 16 |
Depreciation and amortization | 151 |  |  | 133 |
Lease liability | 32 |  |  | 31 |
Net unrealized decline of investments | 77 |  |  | 89 |
Fair value adjustment to senior notes | 41 |  |  | 41 |
Other, net | — |  |  | 13 |
Deferred income tax assets before valuation allowance | 1,917 |  |  | 1,868 |
Valuation allowance | (18) |  |  | (15) |
Deferred income tax assets net of valuation allowance | 1,899 |  |  | 1,853 |
Deferred income tax liabilities: |  |  |
Lloyds year of account deferral | (19) |  |  | (13) |
Contingency reserve | (27) |  |  | (50) |
Deferred policy acquisition costs | (143) |  |  | (144) |
Investment related | (43) |  |  | (13) |
Right-of-use asset | (25) |  |  | (24) |
Other | (6) |  |  | — |
Total deferred income tax liabilities | (263) |  |  | (244) |
Net deferred income tax assets | $ | 1,636 |  |  | $ | 1,609 |
The Company provides a valuation allowance to reduce the net value of certain deferred income tax assets to an amount which management expects to more likely than not be realized. As of December 31, 2024, the Company’s valuation allowance was $18 million, compared to $15 million at December 31, 2023. The valuation allowance at December 31, 2024, was primarily attributable to valuation allowances on the Company’s Australia, Gibraltar and Hong Kong operations and certain other deferred income tax assets relating to tax attributes that have a limited use. At December 31, 2024, the Company’s net operating loss carryforwards and tax credits were as follows:
| Year Ended December 31,
| 2024 |  | Expiration
Operating Loss Carryforwards |  |  |
United Kingdom | $ | 146 |  |  | No expiration
Ireland | 26 |  |  | No expiration
Australia | 43 |  |  | No expiration
Hong Kong | 35 |  |  | No expiration
Gibraltar | 26 |  |  | No expiration
Cyprus | 1 |  |  | No expiration
United States (1) | 70 |  |  | 2029 - 2038
Tax Credits |  |  |
U.K. foreign tax credits | 14 |  |  | No expiration
U.S. foreign tax credits | 8 |  |  | 2029 - 2033
(1) The Company’s U.S. operations have recorded $70 million of net operating loss (“NOL”) carryforwards that are subject to annual usage limitations under Section 382 of the Internal Revenue Code (“the Code”). The Company’s U.S. mortgage operations are eligible for a tax deduction, subject to certain limitations, under Section 832(e) of the Code for amounts required by state law or regulation to be set aside in statutory contingency reserves. The deduction is allowed only to the extent that the Company purchases non-interest bearing U.S. Mortgage Guaranty Tax and Loss Bonds (“T&L Bonds”) issued by the U.S. Treasury Department in an amount equal to the tax benefit derived from deducting any portion of the statutory contingency reserves. T&L Bonds are reflected in ‘other assets’ on the Company’s balance sheet and totaled approximately $47 million at December 31, 2024, compared to $42 million at December 31, 2023. Deferred income tax liabilities have not been accrued with respect to the undistributed earnings of the Company's U.S., U.K. and Ireland subsidiaries as it is the Company’s intention that all such earnings will be indefinitely reinvested. If the earnings were to be distributed, as dividends or otherwise, such amounts may be subject to withholding tax in the jurisdiction of the paying entity. The Company does not intend to indefinitely reinvest earnings from the Company's Canada subsidiary, however, no income or withholding taxes have been accrued as the Canada subsidiary does not have positive cumulative earnings and profits and therefore a distribution from this particular subsidiary would not be subject to income taxes or withholding taxes. Potential tax implications of repatriation from the Company’s unremitted earnings that are indefinitely reinvested are driven by facts at the time of distribution. Therefore, it is not practicable to estimate the income tax liabilities that might be incurred if such earnings were remitted. Distributions from the U.K. or Ireland would not be subject to withholding tax and no deferred income tax liability would need to be accrued. The Company recognizes interest and penalties relating to unrecognized tax benefits in the provision for income taxes. As of December 31, 2024, the Company’s total unrecognized tax benefits, including interest and penalties, were $5 million. If recognized, the full amount of the unrecognized tax benefit would impact the consolidated effective tax rate. A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows:
| December 31,
| 2024 |  | 2023
Balance at beginning of year | $ | 2 |  |  | $ | 2 |
Additions based on tax positions related to the current year | 1 |  |  | — |
Additions for tax positions of prior years | 2 |  |  | — |
Reductions for tax positions of prior years | — |  |  | — |
Settlements | — |  |  | — |
Balance at end of year | $ | 5 |  |  | $ | 2 |
The Company, its subsidiaries and branches file income tax returns in various federal, state and local jurisdictions. The following table details open tax years that are potentially subject to examination by local tax authorities, in the following major jurisdictions:
Jurisdiction |  | Tax Years
United States |  | 2019-2024
United Kingdom |  | 2022-2024
Ireland |  | 2020-2024
Switzerland |  | 2020-2024
Australia |  | 2019-2024
Canada |  | 2020-2024
Gibraltar |  | 2019-2024
As of December 31, 2024, the Company’s current income tax recoverable (included in “Other assets”) was $3 million.

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