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TAXATION
 12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
TAXATION TAXATION
Through December 31, 2024 RenaissanceRe and its Bermuda subsidiaries were not subject to any income or capital gains taxes in Bermuda. A 15% corporate income tax applies to the Company’s Bermuda operations, except for the Bermuda operations of the Company’s joint ventures and managed funds, starting in 2025 as a result of the enactment of the Bermuda Corporate Income Tax Act 2023 (“CIT”) on December 27, 2023. Furthermore, the Company generally expects that the profits generated in Bermuda on or after January 1, 2025 by the Company’s joint ventures and managed funds, except to the extent those profits are attributable to redeemable noncontrolling interests, will also be taxed at 15% as a result of the enactment or expected enactment of provisions similar to the global anti-base erosion model rules (“GloBE Rules”) by many of the jurisdictions in which the Company operates. As a result, the Company expects its income taxes to increase beginning in 2025.
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 at an expected tax rate of 5.0%. The Company has not accrued withholding taxes on the unremitted earnings of RenaissanceRe Finance to date as there is no intention to remit such earnings. The cumulative amount that would be subject to withholding tax, if distributed, is not practicable to compute. The Company also has operations in Ireland, the U.K., Singapore, Switzerland, Luxembourg, Canada and Australia which are subject to income taxes imposed by the respective jurisdictions in which they operate. Withholding taxes would not be expected to apply to dividends paid to RenaissanceRe from its operations in Ireland, the U.K., Singapore, Switzerland, Luxembourg, and Australia.
The following is a summary of the Company’s income (loss) before taxes allocated between domestic and foreign operations:
Year ended December 31,202420232022
Domestic
Bermuda
$2,704,721 $2,622,066 $(672,950)
Foreign
Singapore
61,570 64,003 112 
Ireland
2,650 1,730 6 
U.S.
93,606 308,768 (367,799)
Australia
14,487 7,570 (29,214)
Switzerland
57,585 (22,016)(72,773)
Luxembourg
(50)(16)— 
Canada
(3,501)2,040 — 
U.K.
62,092 125,915 (76,217)
Income (loss) before taxes$2,993,160 $3,110,060 $(1,218,835)
Income tax benefit (expense) is comprised as follows:
Income tax benefit (expense)
CurrentDeferredTotal
Year ended December 31, 2024$(56,718)$24,090 $(32,628)
Year ended December 31, 2023
$(57,422)$567,489 $510,067 
Year ended December 31, 2022
$(3,078)$62,097 $59,019 
The Company’s expected income tax provision computed on pre-tax income (loss) at the weighted average tax rate has been calculated as the sum of the pre-tax income (loss) in each jurisdiction multiplied by that jurisdiction’s applicable statutory tax rate. Statutory tax rates of 0.0% in Bermuda, 21.0% in the U.S., 12.5% in Ireland, 25.0% in the U.K., 17.0% in Singapore, 19.7% in Switzerland, 24.9% in Luxembourg, 26.5% in Canada and 30.0% in Australia have been used.
The Company’s effective income tax rate, which it calculates as income tax benefit (expense) divided by income (loss) before taxes, may fluctuate significantly from period to period depending on the geographic distribution of pre-tax income (loss) 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 operational 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 currently have a corporate income tax, including the majority of the Company’s catastrophe business, which can result in significant volatility to its pre-tax net income (loss) in any given period. The Company expects its consolidated effective tax rate will increase in 2025 as a result of the enactment of the CIT in Bermuda and the implementation of the GloBE Rules in certain jurisdictions where it operates. In addition, it is possible the Company could be adversely affected by other future changes in tax laws, regulation, or enforcement, any of which could increase the effective tax rate more rapidly or steeply than currently anticipated.
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 31,202420232022
Expected income tax benefit (expense)$(60,684)$(103,963)$114,721 
Nondeductible expenses(1,671)(535)(508)
Reinsurance adjustment4,384 4,746 (1,265)
Effect of change in tax rate(160)(729)7,461 
OECD Pillar Two global minimum tax(16,603)— — 
GAAP to statutory accounting difference(1,113)(1,781)(6,019)
Withholding tax(1,614)(1,078)(2,154)
Recognition of Bermuda net deferred tax asset8,339 593,765 — 
Change in valuation allowance66,198 45,192 (62,133)
Foreign branch adjustments(30,998)(25,908)11,656 
Other1,294 358 (2,740)
Income tax benefit (expense) $(32,628)$510,067 $59,019 
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 31,20242023
Deferred tax assets
Intangible assets$420,143 $408,654 
Value of in-force business167,599 167,599 
Tax loss carryforwards152,864 197,498 
Reserve for claims and claim expenses131,121 95,685 
Unearned premiums59,441 68,408 
Amortization and depreciation23,877 16,386 
Deferred finance charges17,832 19,442 
Accrued expenses4,336 2,849 
Investments2,687 37,044 
Deferred underwriting results1,548 9,373 
 981,448 1,022,938 
Deferred tax liabilities
Deferred acquisition expenses(125,347)(112,157)
VOBA(17,540)(46,109)
Deferred revenue(8,685)— 
U.S. tax accounting method change(7,312)— 
 (158,884)(158,266)
Net deferred tax asset (liability) before valuation allowance822,564 864,672 
Valuation allowance(147,079)(213,277)
Net deferred tax asset (liability)$675,485 $651,395 
A substantial amount of the Company’s net deferred tax asset is separately reflected as an asset in the consolidated balance sheets with the remaining net deferred tax liability recorded in other liabilities.
The Company’s net deferred tax asset primarily relates to net operating loss and capital loss carryforwards, unrealized losses in the U.S. investment portfolio, and GAAP versus tax basis accounting differences relating to unearned premiums, reserves for claims and claim expenses, deferred finance charges, deferred underwriting results, accrued expenses, investments, value of in-force business, intangible assets, VOBA, deferred acquisition expenses and amortization and depreciation. 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. During 2024, the Company recorded a net decrease to the valuation allowance of $66.2 million (2023 - increase of $19.6 million, 2022 - increase of $62.1 million).
A valuation allowance has been provided against certain deferred tax assets in the U.S., Canada, Ireland, the U.K., Luxembourg and Switzerland. These deferred tax assets relate primarily to net operating loss carryforwards, deferred finance charges, capital loss carryforwards and unrealized losses in the U.S. investment portfolio.
In the U.S. and Switzerland, the Company has net operating loss carryforwards of $97.3 million and $350.0 million respectively. Under applicable law, the U.S. and Swiss net operating loss carryforwards will begin to expire in 2037 and 2025 respectively. The Company has net operating loss carryforwards of $141.2 million in the U.K., $8.3 million in Ireland, and $155.7 million in Luxembourg. Under applicable law, the U.K., Ireland and Luxembourg net operating losses can be carried forward for an indefinite period. The Company has capital loss carryforwards of $131.6 million in the U.S. that begin to expire in 2027. The Company has unrealized losses in the U.S. investment portfolio of $60.6 million. These unrealized investment losses do not expire. However, if realized, these losses may only offset realized capital gains and would expire, if unused, at the end of the fifth taxable year following their realization.
The Company made net payments for U.S. federal and state, Canada, Ireland, U.K., Singapore, Switzerland and Australia income taxes of $99.5 million for the year ended 2024 (2023 - net payments of $26.8 million, 2022 - net payments of $3.1 million).
The Company had no unrecognized tax benefits at December 31, 2024 and December 31, 2023. Interest and penalties related to unrecognized tax benefits would be recognized in income tax expense. At December 31, 2024 and December 31, 2023, there were no interest or penalties accrued on unrecognized tax benefits.
The following filed income tax returns are open for examination with the applicable tax authorities: tax years 2018 through 2023 with the U.S.; 2020 through 2023 with Ireland; 2022 through 2023 with the U.K.; 2020 through 2023 with Singapore; 2021 through 2023 with Switzerland; 2020 through 2023 with Australia; 2020 through 2023 with Canada; and 2019 through 2023 with Luxembourg. The Company does not expect the resolution of these open years to have a significant impact on its consolidated statements of operations and financial condition.