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Income Taxes
12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
Income tax expense (benefit) on continuing operations consists of the following:
 Year Ended December 31,
 202420232022
 (In millions)
Current$360 $241 $331 
Deferred(49)108 
 $367 $192 $439 
Total income tax expense was allocated as follows:
Year Ended December 31,
 202420232022
(In millions)
Net earnings from continuing operations$367 $192 $439 
Other comprehensive earnings (loss):  
Unrealized (loss) gain on investments and other financial instruments(35)275 (1,198)
Unrealized (loss) gain on foreign currency translation and cash flow hedging(6)(4)
Changes in current discount rate - future policy benefits 59 (50)203 
Changes in instrument - specific credit risk - market risk benefits (9)18 
F&G 15% Distribution
(3)(35)
Minimum pension liability adjustment— — 
Total income tax expense (benefit) allocated to other comprehensive earnings16 183 (970)
Total income tax expense (benefit)$383 $375 $(531)
A reconciliation of the federal statutory rate to our effective tax rate is as follows:
 Year Ended December 31,
 202420232022
Federal statutory rate21.0 %21.0 %21.0 %
State income taxes, net of federal benefit1.8 2.4 2.0 
Stock compensation(0.5)(0.2)(0.1)
Tax credits(0.7)(1.8)(0.7)
Valuation allowance for deferred tax assets(1.0)5.0 5.4 
Benefit on Capital Loss Carryback— — (1.3)
Officers Compensation0.8 1.2 0.4 
Non-deductible expenses and other, net(0.3)0.1 (1.3)
   Effective tax rate21.1 %27.7 %25.4 %
The significant components of deferred tax assets and liabilities consist of the following:
 December 31,
 20242023
 (In millions)
Deferred Tax Assets:  
Employee benefit accruals$129 $116 
Net operating loss carryforwards115 84 
Tax credits204 119 
Investment securities775 686 
Capital loss carryover19 38 
Life insurance and claim related adjustments451 547 
Funds held under reinsurance agreements822 500 
Market Risk Benefits 56 61 
Bermuda corporate income tax net operating loss carryforward10 24 
Other42 26 
Total gross deferred tax asset2,623 2,201 
Less: valuation allowance164 197 
Total deferred tax asset$2,459 $2,004 
Deferred Tax Liabilities:  
Title plant$(53)$(53)
Amortization of goodwill and intangible assets(71)(98)
Other(11)(25)
Depreciation(24)(29)
Partnerships(198)(152)
Value of business acquired(283)(304)
Deferred acquisition costs(543)(361)
Funds held under reinsurance agreements(945)(621)
Title Insurance reserve discounting(16)(18)
Total deferred tax liability$(2,144)$(1,661)
Net deferred tax asset$315 $343 
 
Our net deferred tax asset was $315 million and $343 million as of December 31, 2024 and 2023, respectively. The significant changes in the deferred taxes are as follows: the deferred tax asset for investment securities increased by $89 million primarily due to unrealized losses recorded for investment securities, of which $26 million was related to unrealized losses in our Title segment and $63 million was related to unrealized losses in our F&G segment's life insurance business. The deferred tax liability related to deferred acquisition costs increased by $182 million, which is consistent with the growth in sales in our F&G segment. The reinsurance receivable deferred tax asset increased by $322 million and the reinsurance receivable deferred tax liability increased by $324 million, both due to the increase in the Modco reinsurance in the F&G segment. The deferred tax asset relating to life insurance receivables decreased by $96 million primarily due to tax reserves increasing more than GAAP reserves by F&G. The tax credits deferred tax asset increased by $85 million, primarily due to additional corporate alternative minimum tax credits at the F&G segment’s life insurance business offset by utilization of low-income housing tax credits at the F&G segment’s life insurance business.
As of December 31, 2024, we have net operating losses ("NOLs") on a pretax basis of $547 million, of which $44 million relates to our Title segment and $503 million relates to our F&G segment's life insurance business, which are available to carryforward and offset future federal taxable income. The Title segment NOLs are U.S. federal NOLs arising from acquisitions made since 2012, including Buyers Protection Group, Inc., Digital Insurance Holdings, Inc. and THL Corporations (ServiceLink). Most of the NOLs are subject to an annual Internal Revenue Code Section 382 limitation. These losses will begin to expire in year 2034 and we fully anticipate utilizing the Title segment losses prior to expiration with the exception of $25 million of gross net operating losses that are offset by a $25 million valuation allowance in the Title segment. The F&G NOLs are indefinite life U.S. federal NOLs arising from the life insurance business.
As of December 31, 2024 and 2023, we had $204 million and $119 million of tax credits, respectively, some of which have expiration dates and will begin to expire between 2029 and 2044. The credits primarily consist of general business credits and corporate alternative minimum tax credits, including $164 million associated with our F&G segment's life insurance business. The F&G segment's corporate alternative minimum tax credit has an indefinite life. We anticipate the remainder of the credits will be utilized prior to expiration with the exception of $30 million relating to general business credits in our Title segment which have a corresponding $30 million valuation allowance recorded.
As of December 31, 2024, a full valuation allowance on the net deferred tax asset related to the Bermuda corporate income tax net operating loss carryforward of $10 million was recorded. The net change in the Bermuda corporate income tax net loss operating carryforward valuation allowance was a $14 million decrease for the year ended December 31, 2024.
As of December 31, 2024, a valuation allowance of $119 million on the net deferred tax asset for capital losses was recorded, of which $71 million related to the Title segment and $48 million related to the F&G segment. The net change in the capital loss valuation allowance was a $20 million decrease for the year ended December 31, 2024. This decrease to the valuation allowance was primarily due to fluctuations in the bond and equity markets, and to capital gains and losses generated in 2024.
As of December 31, 2024 and 2023, there were no unrecognized tax benefits.
 
F&G's life insurance subsidiaries, as well as certain F&G non-life subsidiaries file separate tax returns from the FNF consolidated group. Prepaid expenses and other assets in the accompanying Consolidated Balance Sheets as of December 31, 2024, includes: $20 million of deferred tax assets related to the FNF consolidated group as well as $6 million of tax receivables and $295 million of deferred tax assets related to F&G subsidiaries who file separate tax returns. As of December 31, 2023, prepaid expenses and other assets included $26 million of tax receivables related to the FNF consolidated group as well as $28 million of tax receivables and $372 million of deferred tax assets related to the F&G subsidiaries.
We continue to be a participant in the Internal Revenue Service (“IRS”) Compliance Assurance Process that is a real-time audit. The 2024 U.S. federal income tax return remains open to examination by the IRS. We file income tax returns in various foreign and US state jurisdictions. Our state income tax returns for the 2020 through 2024 tax years remain subject to examination by state jurisdictions. The F&G life insurance group files a separate consolidated return with the IRS. The F&G federal income tax returns for 2020 through the current period remain open to examination by the IRS.
The Organization for Economic Cooperation and Development has developed guidance known as the Global Anti-Base Erosion Pillar Two minimum tax rules, or Pillar Two, which generally provide for a minimum effective tax rate of 15% and are intended to apply to tax years beginning in 2024. As of December 31, 2024, based on the countries in which we do business that have enacted legislation, the Company does not expect these rules to have a material impact on our income tax provision.
The Company considers its non-U.S. earnings to be indefinitely reinvested outside of the U.S. to the extent these earnings are not subject to the U.S. income tax under an anti-deferral tax regime. Given our intent to reinvest these earnings for an indefinite period of time, the Company has not accrued a deferred tax liability on these earnings. A determination of an unrecognized deferred tax liability related to these earnings is not practicable.