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Income Tax
 9 Months Ended
Sep. 30, 2024
Income Tax Disclosure [Abstract]  
Income Tax Disclosure [Text Block] INCOME TAX
The effective tax rate on pre-tax income for the three and nine months ending September 30, 2024, was 26.7% and 24.2%, respectively. The tax rate was higher than the U.S. statutory rate primarily due to adjustments related to tax returns filed during the quarter as well as Subpart F income. These increases were partially offset with benefits received in certain foreign jurisdictions and adjustments to the valuation allowance.
The effective tax rate on pre-tax income for the three and nine months ending September 30, 2023, was 24.2% and 24.9%, respectively. The tax rate was higher than the U.S. statutory rate primarily due to income earned in foreign jurisdictions and adjustments to the valuation allowance. These increases were partially offset with benefits received in certain foreign jurisdictions.
The Inflation Reduction Act of 2022 (“the Act”) was enacted in 2022. For tax years ending after December 31, 2022, the Act imposes a 15% minimum tax on adjusted financial statement income for “applicable corporations” with average financial statement income over $1 billion for the previous 3-year period ending in 2022 or after. The Company is currently evaluating the impact of recent proposed guidance to determine applicability. The Act also imposes a 1% excise tax on stock buybacks of a publicly traded corporation. The Act is not expected to have a material impact to the Company’s tax expense.
Bermuda enacted the Corporate Income Tax Act of 2023 on December 27, 2023. The Bermuda regime, which is effective for fiscal years beginning on or after January 1, 2025, establishes a statutory tax rate of 15%, applicable to companies with annual revenue of EUR 750 million or more. This enactment did not have a material impact on the Company’s financial position or results from operations.
The Organization for Economic Cooperation and Development developed the Model Global Anti-Base Erosion (“GloBE”) rules under Pillar II establishing a Global Minimum Tax to ensure multinational enterprises with consolidated revenue of more than EUR 750 million pay at least an effective tax rate of 15% on income arising in each jurisdiction in which they operate. The
GloBE model rules serve as a template to allow for each jurisdiction to modify and incorporate into domestic law. As of September 30, 2024, many of the jurisdictions in which the Company operates enacted Pillar II legislation into domestic law with an effective date of January 1, 2024. Guidance is expected to continue throughout 2024 and beyond. The Company continues to evaluate the expected impact of the new law.