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Income Taxes (Tables)
12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
Components of income taxes attributable to operations
The components of income taxes attributable to operations were as follows:
Year Ended December 31,
202420232022
Current expense (benefit):
United States$332 $251 $195 
Non-U.S.65 37 
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 
Schedule of income or loss before income taxes by jurisdiction
The Company’s income or loss before income taxes was earned in the following jurisdictions:
Year Ended December 31,
202420232022
Income (Loss) Before Income Taxes:
Bermuda$2,611 $2,099 $986 
United States1,438 1,239 401 
Other625 232 175 
Total$4,674 $3,570 $1,562 
Reconciliation of the differences between the provision for income taxes and the expected tax provision at the weighted average tax rate
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,
202420232022
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 rate12 (1,179)(5)
Share based compensation(11)(13)(9)
Tax credits(5)(3)(10)
Base eroding tax/Alternative minimum tax
State taxes, net of U.S. federal tax benefit11 
Change in valuation allowance(23)
Uncertain tax position— — 
Dividend withholding taxes11 
Other— 
Income tax expense (benefit)$362 $(873)$80 
Significant components of deferred income tax assets and liabilities
Significant components of the Company’s deferred income tax assets and liabilities were as follows:
December 31,
20242023
Deferred income tax assets:
Net operating loss$77 $93 
Discounting of net loss reserves203 219 
Net unearned premium reserve190 133 
Compensation liabilities75 64 
Foreign tax credit carryforward22 16 
Goodwill and intangible assets1,034 1,020 
Bad debt reserves15 16 
Depreciation and amortization151 133 
Lease liability32 31 
Net unrealized decline of investments77 89 
Fair value adjustment to senior notes41 41 
Other, net— 13 
Deferred income tax assets before valuation allowance1,917 1,868 
Valuation allowance(18)(15)
Deferred income tax assets net of valuation allowance1,899 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 
Summary of operating loss carryforwards
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
Ireland26 No expiration
Australia43 No expiration
Hong Kong35 No expiration
Gibraltar26 No expiration
CyprusNo expiration
United States (1)70 
2029 - 2038
Tax Credits
U.K. foreign tax credits14 No expiration
U.S. foreign tax credits2029 - 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”).
Summary of tax credit carryforwards
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
Ireland26 No expiration
Australia43 No expiration
Hong Kong35 No expiration
Gibraltar26 No expiration
CyprusNo expiration
United States (1)70 
2029 - 2038
Tax Credits
U.K. foreign tax credits14 No expiration
U.S. foreign tax credits2029 - 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”).
Reconciliation of the beginning and ending amount of unrecognized tax benefits A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows:
December 31,
20242023
Balance at beginning of year$$
Additions based on tax positions related to the current year— 
Additions for tax positions of prior years— 
Reductions for tax positions of prior years— — 
Settlements— — 
Balance at end of year$$
Summary of open tax years potentially subject to examination, by jurisdiction The following table details open tax years that are potentially subject to examination by local tax authorities, in the following major jurisdictions:
JurisdictionTax Years
United States
2019-2024
United Kingdom
2022-2024
Ireland
2020-2024
Switzerland
2020-2024
Australia
2019-2024
Canada
2020-2024
Gibraltar
2019-2024