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Income Taxes
12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
Income Tax Disclosure [Text Block]
15. Income Taxes

Income (loss) before income taxes includes the following components, based on country of domicile.

Years Ended December 31,
(dollars in thousands)202420232022
U.S. operations$2,428,694 $1,711,849 $(109,311)
Foreign operations1,209,006 941,857 (42,255)
Income (loss) before income taxes$3,637,700 $2,653,706 $(151,566)
Income tax expense (benefit) includes the following components, based on the taxing authority to which taxes are paid. The Company's most significant U.K. and Bermuda subsidiaries have elected to be taxed as domestic corporations for U.S. tax purposes. U.S. income taxes have not been recognized on any undistributed earnings of the Company's foreign subsidiaries that are considered indefinitely reinvested, the amount of which is not material to the consolidated financial statements. U.S. income tax includes applicable state income tax expense.
Years Ended December 31,
(dollars in thousands)202420232022
Current:
U.S. income tax$271,801 $249,149 $222,074 
Foreign income tax123,933 69,669 12,042 
Total current tax expense395,734 318,818 234,116 
Deferred:
U.S. income tax399,169 250,041 (301,423)
Foreign income tax(4,609)(16,243)19,098 
Total deferred tax expense (benefit)394,560 233,798 (282,325)
Income tax expense (benefit)$790,294 $552,616 $(48,209)

The Company made net income tax payments of $382.5 million, $280.7 million and $251.5 million in 2024, 2023 and 2022, respectively. Income taxes payable were $40.3 million and $29.4 million at December 31, 2024 and 2023, respectively, and were included in other liabilities on the consolidated balance sheets. Income taxes receivable were $13.3 million and $0.3 million at December 31, 2024 and 2023, respectively, and were included in other assets on the consolidated balance sheets.

The following table presents a reconciliation of the Company's income taxes using the U.S. corporate income tax rate to the Company's income tax expense (benefit).

Years Ended December 31,
(dollars in thousands)202420232022
U.S. corporate tax rate$763,917 21.0 %$557,278 21.0 %$(31,829)21.0 %
Increase (decrease) resulting from:
State income taxes, net of U.S. federal income tax benefit
39,770 1.127,007 1.03,369 (2.2)
Tax-exempt investment income(14,830)(0.4)(15,328)(0.6)(16,063)10.6
Foreign operations12,985 0.310,854 0.45,335 (3.5)
Impairment of goodwill — 16,800 (11.1)
Markel CATCo Re income not subject to tax
(12,201)(0.3)(15,013)(0.6)(18,871)12.5
Other653 0.0(12,182)(0.4)(6,950)4.5
Income tax expense (benefit)$790,294 21.7 %$552,616 20.8 %$(48,209)31.8 %
The following table presents the components of domestic and foreign deferred tax assets and liabilities.

December 31,
(dollars in thousands)20242023
Assets:
Unpaid losses and loss adjustment expenses$233,583 $216,863 
Lease liabilities172,131 161,350 
Unearned premiums164,485 168,172 
Accrued incentive compensation51,943 52,853 
Tax credit carryforwards45,481 25,396 
Net operating loss carryforwards37,168 43,439 
Life and annuity benefits29,143 39,729 
Other differences between financial reporting and tax bases106,667 93,693 
Total gross deferred tax assets840,601 801,495 
Less valuation allowance(33,292)(13,916)
Total gross deferred tax assets, net of allowance807,309 787,579 
Liabilities:
Investments1,566,540 1,196,717 
Deferred policy acquisition costs173,742 176,382 
Goodwill and other intangible assets170,941 175,767 
Right-of-use lease assets162,628 152,939 
Property, plant and equipment160,615 152,149 
Other differences between financial reporting and tax bases113,873 104,024 
Total gross deferred tax liabilities2,348,339 1,957,978 
Net deferred tax liability$1,541,030 $1,170,399 

Deferred tax assets and liabilities are recorded on the consolidated balance sheets on a net basis by taxing jurisdiction. As of December 31, 2024 and 2023, the Company's consolidated balance sheets included net deferred tax liabilities of $1.6 billion and $1.2 billion, respectively, in other liabilities and net deferred tax assets of $40.0 million and $23.5 million, respectively, in other assets.

At December 31, 2024, the Company had tax credit carryforwards of $45.5 million, substantially all of which related to foreign tax credits to be used against U.S. income tax. The Company expects to utilize all tax credit carryforwards before expiration. The earliest any of these credits will expire is 2034.

At December 31, 2024, the Company had deferred tax assets of $28.9 million for U.S. state net operating loss carryforwards and $7.7 million for foreign net operating loss carryforwards, which are available to offset future taxable income in certain U.S. state and foreign jurisdictions, respectively. The Company's ability to benefit from the majority of these net operating loss carryforwards is not subject to expiration. As described below, the deferred tax assets related to losses at certain of the Company's subsidiaries and branches are offset by valuation allowances.

At December 31, 2024, the Company had total gross deferred tax assets of $840.6 million. The Company has a valuation allowance of $33.3 million to offset gross deferred tax assets at certain of the Company's international subsidiaries and branches. The Company believes that it is more likely than not that it will realize the remaining $807.3 million of gross deferred tax assets through generating taxable income or the reversal of existing temporary differences attributable to the gross deferred tax liabilities. Additionally, the Company's net deferred tax liability for investments includes deferred tax assets attributed to its unrealized losses on fixed maturity securities. The Company has the ability and intent to execute a tax planning strategy such that it is more likely than not that all of these deferred tax assets will be realized.

At December 31, 2024, the Company did not have any material unrecognized tax benefits. The Company does not anticipate any changes in unrecognized tax benefits during 2025 that would have a material impact on the Company's income tax provision.
The Company is subject to income tax in the U.S. and in foreign jurisdictions. The Internal Revenue Service is currently examining the Company's 2017 U.S. federal income tax return. The Company believes its income tax liabilities are adequate as of December 31, 2024, however, these liabilities could be adjusted as a result of this examination. With few exceptions, including the 2017 U.S. federal income tax return, the Company is no longer subject to income tax examination by tax authorities for years ended before January 1, 2021.