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Income Taxes

12 Months Ended

Dec. 31, 2024

Income Taxes

Income Taxes

14. Income Taxes

Income Taxes (Benefits)

Our income taxes (benefits) were as follows:

​

​	​	​	​	​	​	​	​	​	​	​
​	​	For the year ended December 31,
​		2024			2023			2022
​	​	(in millions)
Current income taxes (benefits):	​	​	​	​	​	​	​	​	​	​
U.S. federal	​	$	217.8	​	$	81.5	​	$	(56.3)	​
State	​	​	33.3	​	​	20.1	​		20.7	​
Foreign	​	​	37.0	​	​	38.8	​		53.1	​
Tax benefit of operating loss carryforward	​	​	(3.7)	​	​	(14.5)	​		(9.5)	​
Total current income taxes	​	​	284.4	​	​	125.9	​		8.0	​
Deferred income taxes (benefits):	​	​	​	​	​	​	​	​	​	​
U.S. federal	​	​	(12.1)	​	​	(63.2)	​		1,189.7	​
State	​	​	12.7	​	​	0.1	​		8.0	​
Foreign	​	​	6.7	​	​	5.9	​		(16.2)	​
Total deferred income taxes (benefits)	​	​	7.3	​	​	(57.2)	​		1,181.5	​
Income taxes	​	$	291.7	​	$	68.7	​	$	1,189.5	​

​

Our income before income taxes was as follows:

​

​	​	​	​	​	​	​	​	​	​	​
​	​	For the year ended December 31,								​
​		2024			2023			2022
​	​	(in millions)								​
Domestic		$	1,662.1		$	412.8		$	5,766.1	​
Foreign	​	​	227.5	​	​	326.0	​	​	220.9	​
Total income before income taxes		$	1,889.6		$	738.8		$	5,987.0	​

​

Effective Income Tax Rate

Our provision for income taxes may not have the customary relationship of taxes to income. A reconciliation between the U.S. corporate income tax rate and the effective income tax rate was as follows:

​

​	​	​	​	​	​	​	​
​	​	For the year ended December 31,
​		2024		2023		2022
U.S. corporate income tax rate		21	%	21	%	21	%
Dividends received deduction	​	(4)	​	(10)	​	(1)	​
Tax credits	​	(4)	​	(8)	​	(1)	​
Impact of equity method presentation	​	(1)	​	(4)	​	—	​
Interest exclusion from taxable income	​	(1)	​	(3)	​	—	​
Foreign currency inflation	​	—	​	(1)	​	—	​
Impact of noncontrolling interest presentation	​	—	​	(1)	​	—	​
Low income housing tax credit amortization	​	2	​	5	​	—	​
State income taxes	​	2	​	2	​	—	​
Valuation allowance	​	1	​	1	​	—	​
Global Intangible Low-Taxed Income	​	—	​	7	​	1	​
Other	​	(1)	​	—	​	—	​
Effective income tax rate	​	15	%	9	%	20	%

​

​

Unrecognized Tax Benefits

Our changes in unrecognized tax benefits were as follows:

​

​	​	​	​	​	​	​	​	​	​	​
​	​	For the year ended December 31,
​		2024			2023			2022
​	​	(in millions)
Balance at beginning of period	​	$	39.3	​	$	42.2	​	$	45.5	​
Additions based on tax positions related to the current year	​	​	0.3	​	​	0.3	​		—	​
Reductions for tax positions related to the current year	​	​	(3.2)	​	​	(3.2)	​		(3.3)	​
Balance at end of period (1)	​	$	36.4	​	$	39.3	​	$	42.2	​

(1) If recognized, $1.6 million of the amount of unrecognized tax benefits would reduce our 2024 effective income tax rate. We recognize interest and penalties related to uncertain tax positions in operating expenses within the consolidated statements of operations.

As of December 31, 2024 and 2023, we had recognized $2.0 million and $1.8 million of accumulated pre-tax interest and penalties related to unrecognized tax benefits, respectively. We do not believe there is a reasonable possibility the total amount of the unrecognized tax benefits will significantly increase or decrease in the next twelve months considering recent settlements and the status of current and pending Internal Revenue Service (“IRS”) examinations.

Net Deferred Income Taxes

Deferred income taxes reflect the net tax effects of temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for income tax purposes. Our significant components of net deferred income taxes were as follows:

​

​	​	​	​	​	​	​	​
​	​	December 31,
​		2024			2023
​	​	(in millions)
Deferred income tax assets:	​	​	​	​	​	​	​
Net operating and capital loss carryforwards	​	$	107.4	​	$	123.0	​
Tax credit carryforwards	​	​	15.2	​	​	64.2	​
Net unrealized losses on available-for-sale securities	​	​	1,250.2	​	​	1,092.9	​
Employee benefits	​	​	334.3	​	​	315.4	​
Gross deferred income tax assets	​	​	1,707.1	​	​	1,595.5	​
Valuation allowance	​	​	(71.4)	​	​	(58.8)	​
Total deferred income tax assets	​	​	1,635.7	​	​	1,536.7	​
Deferred income tax liabilities:	​	​	​	​	​	​	​
Deferred acquisition costs	​	​	(689.7)	​	​	(679.2)	​
Investments, including derivatives	​	​	(217.1)	​	​	(240.9)	​
Funds withheld embedded derivative	​	​	(651.7)	​	​	(575.5)	​
Real estate	​	​	(127.1)	​	​	(136.7)	​
Intangible assets	​	​	(355.5)	​	​	(384.2)	​
Insurance liabilities	​	​	(1,008.1)	​	​	(886.1)	​
Other deferred income tax liabilities	​	​	(85.4)	​	​	(6.3)	​
Total deferred income tax liabilities	​	​	(3,134.6)	​	​	(2,908.9)	​
Total net deferred income tax liabilities	​	$	(1,498.9)	​	$	(1,372.2)	​

​

Our net deferred income taxes by jurisdiction were as follows:

​

​	​	​	​	​	​	​	​
​	​	December 31,
​		2024			2023
​	​	(in millions)
Deferred income tax assets:	​	​	​	​	​	​	​
State	​	$	61.9	​	$	77.9	​
Foreign	​	​	145.2	​	​	163.2	​
Net deferred income tax assets	​	​	207.1	​	​	241.1	​
Deferred income tax liabilities:	​	​	​	​	​	​	​
U.S. federal	​	​	(1,416.1)	​	​	(1,312.9)	​
Foreign	​	​	(289.9)	​	​	(300.4)	​
Net deferred income tax liabilities	​	​	(1,706.0)	​	​	(1,613.3)	​
Total net deferred income tax liabilities	​	$	(1,498.9)	​	$	(1,372.2)	​

​

In management’s judgment, total deferred income tax assets are more likely than not to be realized. Included in the deferred income tax asset are federal net operating loss, capital loss and tax credit carryforwards available to offset future taxable income or income taxes. As of December 31, 2024 and 2023, we had net operating loss carryforwards for U.S. federal income tax purposes of $16.9 million and $0.0 million, respectively, which may be carried forward indefinitely. In addition, as of December 31, 2024 and 2023, we had federal capital loss carryforwards of $69.9 million and $155.2 million, respectively. If unused, these federal capital loss carryforwards will expire in 2028. Furthermore, as of December 31, 2024 and 2023, we had federal tax credit carryforwards of $15.2 million and $64.2 million, respectively. As of December 31, 2024, these carryforwards are anticipated to be utilized and can be carried forward indefinitely; therefore, no valuation allowance has been provided for the related deferred income tax asset.

As of December 31, 2024 and 2023, state net operating loss carryforwards were $288.3 million and $312.3 million, respectively, and will expire between 2032 and 2040. As of December 31, 2024 and 2023, foreign net operating loss carryforwards were $264.3 million and $257.3 million, respectively, with some expiring in 2024 while others never expire. We maintain valuation allowances by jurisdiction against the deferred income tax assets related to some of these carryforwards and other items, as utilization of these income tax benefits fail the more likely than not criteria in certain jurisdictions. As of December 31, 2024 and 2023, valuation allowances of $71.4 million and $58.8 million, respectively, had been recorded against the income tax benefits associated primarily with foreign net operating loss carryforwards and net unrealized capital losses on benefit plan trusts. Adjustments to the valuation allowance will be made if there is a change in management’s assessment of the amount of the deferred income tax assets that are more likely than not to be realized.

Deferred tax liabilities are recognized for taxes payable on the unremitted earnings from foreign operations of our subsidiaries, except where it is our intention to indefinitely reinvest a portion or all of these undistributed earnings. As of December 31, 2024 and 2023, any applicable taxes that would be due upon repatriation were not provided on approximately $1,276.3 million and $1,362.6 million, respectively, of such accumulated but undistributed earnings from operations of foreign subsidiaries. We currently do not intend to repatriate these unremitted earnings because we have several liquidity options to fund our domestic operations and obligations. These options include investing and financing activities, such as issuing debt, as well as cash flow and dividends from domestic operations. As of December 31, 2024 and 2023, it was not practicable to determine the amount of the unrecognized deferred tax liability that would arise if foreign earnings were remitted, due to the complexity of our international holding company structure, and other significant tax attributes and varying state tax laws. Taxes on remittances would be limited to foreign currency gains or losses, foreign withholding taxes and state income taxes, which we would anticipate to be immaterial. As of December 31, 2024, deferred taxes were also not provided on the approximately $106.2 million of excess book carrying value over tax basis with respect to the original investment in our foreign subsidiaries. A tax liability will be recognized when we no longer plan to indefinitely reinvest a portion or all of these earnings or when we plan to sell a portion or all of our ownership interest.

Effects of Tax Legislation

We are currently monitoring global enactments of the Pillar Two model rules proposed by the Organisation for Economic Co-operation and Development, which brings forward a 15% global minimum tax. Generally, a company is required to consider the impact of new tax law on realizability of its deferred tax assets (“DTAs”), including determination of whether a change to its valuation allowance amounts is necessary. We made an accounting policy election to disregard the Pillar Two model rules when evaluating DTAs and rather recognize a current period tax expense when incurred.

The Inflation Reduction Act of 2022 (“IRA 2022”) was enacted by the U.S. government on August 16, 2022. The IRA 2022 implements a new corporate alternative minimum tax (“CAMT”) effective January 1, 2023. We are an “Applicable Corporation,” which requires computation of the U.S. federal income tax liability under two systems, the U.S. regular corporate tax (“RCT”) and the CAMT. Although the CAMT may apply in any given year when tentative minimum tax (“TMT”) exceeds the RCT liability, as a “prepayment” the CAMT generates a corresponding alternative minimum tax credit (“AMTC”). The AMTC is accounted for as a DTA with an indefinite carryover life recoverable in years when the RCT liability exceeds TMT.

The tax accounting consequences of a change in tax law is required to be recognized in the period legislation is enacted. Generally, a company is also required to consider the impact of new tax law on realizability of its DTAs, including determination of whether a change to its valuation allowance amounts is necessary. We made an accounting policy election to disregard our CAMT status when evaluating DTAs under the RCT system associated with the IRA 2022.

Other Tax Information

Income tax returns are filed in U.S. federal jurisdiction as well as various states and foreign jurisdictions where we and one or more of our subsidiaries conduct business. Although determined by jurisdiction, with few exceptions our tax uncertainties relate primarily to U.S. federal income tax matters. The IRS has completed examination of our consolidated U.S. federal income tax returns for years prior to 2015.

The U.S. federal statute of limitations has expired for years prior to 2015. The IRS is currently auditing our U.S. federal income tax returns for tax years 2015-2018 and 2019-2022. The statutes remain open through normal statute extensions. We do not expect the results of these audits, subsequent related adjustments or developments in other tax areas for all open tax years to significantly change the possible increase in the amount of unrecognized tax benefits, but the outcome of tax reviews is uncertain and unforeseen results can occur.

We believe we have adequate defenses against, or sufficient provisions for, contested issues, but final resolution could take several years depending on whether legal remedies are pursued. Consequently, we do not believe issues that might arise in tax years subsequent to 2014 will have a material impact on our net income.

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