TAXATION

Under current Bermuda law, RenaissanceRe and its Bermuda subsidiaries are not subject to any income or capital gains taxes. In the event that such taxes are imposed, RenaissanceRe and its Bermuda subsidiaries would be exempted from any such tax until March 2035 pursuant to the Bermuda Exempted Undertakings Tax Protection Act 1966, and Amended Acts of 1987 and 2011, respectively.

RenaissanceRe Finance and its subsidiaries are subject to income taxes imposed by U.S. federal and state authorities and file a consolidated U.S. federal income tax return. Should the U.S. subsidiaries pay a dividend to RenaissanceRe, withholding taxes would apply to the extent of current year or accumulated earnings and profits. The Company also has operations in Ireland, the U.K., and Singapore which are subject to income taxes imposed by the respective jurisdictions in which they operate.

The Company is not subject to income taxation other than as stated above. There can be no assurance that there will not be changes in applicable laws, regulations or treaties, which might require the Company to change the way it operates or become subject to taxation.

The following is a summary of the Company’s income (loss) from continuing operations before taxes allocated between domestic and foreign operations:




Year ended December 31,	2015			2014			2013
Domestic
Bermuda	$	511,114		$	701,476		$	873,103
Foreign
United Kingdom	(22,712		)	(3,166		)	(12,678		)
U.S.	12,523			(10,977		)	(20,019		)
Ireland	188			1,549			1,855
Singapore	(4,737		)	(2,018		)	(1,223		)
Income from continuing operations before taxes	$	496,376		$	686,864		$	841,038

Income tax (expense) benefit is comprised as follows:




Year ended December 31, 2015	Current			Deferred		Total
Total income tax (expense) benefit	$	(3,471	)	$	49,337	$	45,866
Year ended December 31, 2014
Total income tax (expense) benefit	$	(699	)	$	91	$	(608	)
Year ended December 31, 2013
Total income tax (expense) benefit	$	(2,005	)	$	313	$	(1,692	)

The Company’s expected income tax provision computed on pre-tax income at the weighted average tax rate has been calculated as the sum of the pre-tax income in each jurisdiction multiplied by that jurisdiction’s applicable statutory tax rate. Statutory tax rates of 0.0%, 35.0%, 12.5%, 20.2% and 17.0% have been used for Bermuda, the U.S., Ireland, the U.K. and Singapore, respectively.

The Company’s effective income tax rate, which it calculates as income tax expense divided by net income before taxes, may fluctuate significantly from period to period depending on the geographic distribution of pre-tax net income in any given period between different jurisdictions with comparatively higher tax rates and those with comparatively lower tax rates. The geographic distribution of pre-tax income (loss) can vary significantly between periods due to, but not limited to, the following factors: the business mix of net premiums written and earned; the geographic location, the size and the nature of net claims and claim expenses incurred; the amount and geographic location of operating expenses, net investment income, net realized and unrealized gains (losses) on investments; outstanding debt and related interest expense; and the amount of specific adjustments to determine the income tax basis in each of the Company’s operating jurisdictions. In addition, a significant portion of the Company’s gross and net premiums are currently written and earned in Bermuda, which does not have a corporate income tax, including the majority of the Company’s catastrophe business, which can result in significant volatility to its pre-tax income (loss) in any given period.

A reconciliation of the difference between the provision for income taxes and the expected tax provision at the weighted average tax rate is as follows:




Year ended December 31,	2015			2014			2013
Expected income tax benefit	$	1,011		$	4,725		$	9,930
Change in valuation allowance	43,808			(5,554		)	(8,574		)
Tax exempt income	4,939			671			129
Transaction costs	3,654			—			—
Non-taxable foreign exchange (losses) gains	(1,897		)	885			(88		)
Withholding tax	(3,036		)	(327		)	(1,717		)
Other	(2,613		)	(1,008		)	(1,372		)
Income tax benefit (expense)	$	45,866		$	(608	)	$	(1,692	)

The tax effects of temporary differences that give rise to significant portions of the deferred tax assets and deferred tax liabilities are presented below:




At December 31,	2015			2014
Deferred tax assets
Tax loss and credit carryforwards	$	40,512		$	37,933
Reserve for claims and claim expenses	29,833			301
Deferred interest expense	18,901			17,066
Accrued expenses	15,730			3,680
Unearned premiums	8,946			892
Deferred underwriting results	421			1,586
Amortization and depreciation	—			1,686
Investments	—			290
	114,343			63,434
Deferred tax liabilities
Deferred acquisition expenses	(10,741		)	(1,460		)
Amortization and depreciation	(5,899		)	(54		)
Investments	(1,479		)	—
	(18,119		)	(1,514		)
Net deferred tax asset before valuation allowance	96,224			61,920
Valuation allowance	(17,852		)	(61,660		)
Net deferred tax asset	$	78,372		$	260

During 2015, the Company recorded a net decrease to the valuation allowance of $43.8 million (2014 – increase of $5.6 million, 2013 – increase of $21.0 million). The Company’s net deferred tax asset primarily relates to net operating loss carryforwards and GAAP versus tax basis accounting differences relating to reserves for claims and claim expenses, deferred interest expense, accrued expenses, unearned premiums, deferred underwriting results, deferred acquisition expenses, amortization and depreciation and investments. The Company’s valuation allowance assessment is based on all available information including projections of future GAAP taxable income from each tax-paying component in each tax jurisdiction. Losses incurred within the U.S. tax-paying subsidiaries in the fourth quarter of 2011 were significant enough to result in a cumulative GAAP taxable loss at the U.S. tax-paying subsidiaries for the three year period ended December 31, 2011. The Company concluded that a valuation allowance was required from 2011 through the period ended December 31, 2014 as the Company remained in a cumulative GAAP taxable loss position for this period, among other facts. As of December 31, 2014, the U.S. valuation allowance was $48.5 million. In the first quarter of 2015, as a result of expected profits in the U.S. based operations due principally to the Platinum acquisition, the Company determined it was more likely than not it would be able to recover a substantial portion of the U.S. net deferred tax asset and thus reduced the U.S. valuation allowance from $48.5 million to $1.0 million. Factors that led to this determination included the combined cumulative GAAP taxable income position of the Company’s U.S.-based operations (including the entities acquired) along with the future expected profits of the combined operations.

A valuation allowance has been provided against deferred tax assets in Ireland, the U.K., and Singapore. These deferred tax assets relate primarily to net operating loss carryforwards.

In the U.S., the Company has net operating loss carryforwards of $66.1 million. Under applicable law, the U.S. net operating loss carryforwards will begin to expire in 2031. In Ireland, the Company has net operating loss carryforwards of $11.0 million. In the U.K., the Company has net operating loss carryforwards of $59.3 million. In Singapore, the Company has net operating loss carryforwards of $6.5 million. Under applicable law, the Irish, U.K. and Singapore net operating losses can be carried forward for an indefinite period.

The Company had a net payment for U.S. federal, Irish, U.K. and Singapore income taxes of $10.3 million for the year ended 2015 (2014 – net payment of $1.1 million, 2013 – net payment of $1.2 million).

The Company has unrecognized tax benefits of $Nil as of December 31, 2015 (2014 – $Nil). Interest and penalties related to unrecognized tax benefits would be recognized in income tax expense. At December 31, 2015, interest and penalties accrued on unrecognized tax benefits were $Nil (2014 – $Nil). Income tax returns filed for tax years 2009 through 2014, 2011 through 2014, 2014 and 2012 through 2014, are open for examination by the Internal Revenue Service, Irish tax authorities, U.K. tax authorities, and Singapore tax authorities, respectively. The Company does not expect the resolution of these open years to have a significant impact on its results from operations and financial condition.