Under current Bermuda law, AXIS Capital's Bermuda domiciled subsidiaries are not required to pay any taxes in Bermuda on income or capital gains. The Company has received an assurance from the Minister of Finance in Bermuda that, in the event of any taxes being imposed, it will be exempt from taxation in Bermuda until March 2035. The Company's primary Bermuda subsidiary has an operating branch in Singapore, which is subject to the relevant taxes in that jurisdiction. The Singapore branch is not under examination in that tax jurisdiction but remains subject to examination for tax years 2016 through 2019.

AXIS Capital's U.S. subsidiaries are subject to federal, state and local corporate income taxes, and other taxes applicable to U.S. corporations. The provision for federal income taxes has been determined under the principles of the consolidated tax provisions of the U.S. Internal Revenue Code and regulations. Should the U.S. subsidiaries pay a dividend outside the U.S. group, withholding taxes will apply. The Company's U.S. subsidiaries are not under examination but remain subject to examination for tax years 2016 through 2019.

In Canada, AXIS Capital's U.S. reinsurance company operates through a branch and its U.S. service company has an unlimited liability company subsidiary based in Canada. The Canadian operations are subject to the relevant taxes in that jurisdiction and remain subject to examination for tax years 2015 through 2019.

AXIS Capital had subsidiaries in Ireland, the U.K., Australia, Belgium, Luxembourg, Brazil and Dubai in 2018 and 2017. The Company ceased operations in Australia in 2017. Effective January 1, 2019, AXIS Capital's subsidiary in Belgium was merged into AXIS Specialty Europe. In addition, the Company ceased operations in Luxembourg in December 2019. Consequently, AXIS Capital had subsidiaries in Ireland, the U.K., Brazil and Dubai in 2019. AXIS Capital's Irish operations had branches in the U.K. and Switzerland in 2018 and 2017. Effective January 1, 2019, following the merger of AXIS Specialty Europe and Aviabel SA., AXIS Capital also has branches in Belgium and the Netherlands. Except for Ireland, with respect to a 2016 and 2017 revenue audit, these subsidiaries and their branches are not under examination, but remain subject to examination in all applicable jurisdictions for tax years 2015 through 2019.

In the U.K., the Company operates through Lloyd’s syndicates whose income is subject to tax in the U.K., payable by its corporate members. The income from operations at Lloyd’s is also subject to taxes in other jurisdictions in which Lloyd's operates, including the U.S. Under a Closing Agreement between Lloyd’s and the IRS, Lloyd's corporate members pay U.S. income tax on U.S. connected income written by Lloyd’s syndicates. To the extent that the Lloyd’s syndicates suffer taxes outside the U.K., they may claim a credit for foreign taxes suffered, limited to the U.K. equivalent tax on the same income.




Year ended December 31,	2019			2018			2017

Current income tax expense (benefit)
U.S.	$	12,601		$	(5,401	)	$	(6,207	)
Europe	22,425			10,409			10,249
Other	469			51			—
Deferred income tax expense (benefit)
U.S.	17,665			15,288			18,495
Europe	(29,468		)	(49,833		)	(30,079		)
Total income tax expense (benefit)	$	23,692		$	(29,486	)	$	(7,542	)

Net current tax receivables (payables)	$	13,130		$	9,683		$	(639	)
Net deferred tax assets	18,621			39,775			4,438

Net tax assets	$	31,751		$	49,458		$	3,799

Deferred income taxes reflect the tax impact of temporary differences between the carrying amounts of assets and liabilities for financial reporting and income tax purposes. The following table provides details of the significant components of deferred tax assets and liabilities:




At December 31,	2019			2018

Deferred tax assets:
Discounting of net reserves for losses and loss expenses	$	40,523		$	37,440
Unearned premiums	42,709			40,447
Net unrealized investments losses	—			11,438
Operating and capital loss carryforwards⁽¹⁾	85,901			83,850
Accruals not currently deductible	29,705			32,589
Tax credits	2,956			8,672
Other deferred tax assets	14,355			9,195
Deferred tax assets before valuation allowance	216,149			223,631
Valuation allowance	(18,560		)	(18,955		)
Deferred tax assets net of valuation allowance	197,589			204,676

Deferred tax liabilities:
Deferred acquisition costs	(38,320		)	(39,745		)
Net unrealized investments gains	(30,434		)	—
Intangible assets	(44,199		)	(49,097		)
Equalization reserves	(2,825		)	(22,069		)
Other deferred tax liabilities	(63,190		)	(53,990		)
Deferred tax liabilities	(178,968		)	(164,901		)
Net deferred tax assets	$	18,621		$	39,775




At December 31,	2019		2018

Operating and Capital Loss Carryforwards⁽¹⁾
Singapore (branch) operating loss carryforward	$	103,899	$	79,445
U.K. operating loss carryforward⁽²⁾	431,374		413,504
Ireland operating loss carryforward	9,064		12,756
U.S. operating loss carryforward	—		15,062
Ireland capital loss carryforward	716		716

Tax Credits⁽¹⁾
Ireland foreign tax credit	$	2,092	$	2,248
U.S. alternative minimum tax credit	—		6,026
U.K. tax credit	864		398




At December 31,	2019			2018

Income tax expense:
Valuation allowance - beginning of year	$	13,891		$	16,157
Operating loss carryforwards	2,445			198
Foreign tax credit	(114		)	(1,359		)
U.K. branch assets and other foreign rate differentials	2,338			(205		)
U.S. alternative minimum tax credits	—			(900		)
Valuation allowance - end of year	$	18,560		$	13,891

Accumulated other comprehensive income:
Valuation allowance - beginning of year	5,064			—
Change in investment - related items	(5,064		)	5,064
Valuation allowance - end of year	—			5,064

Total valuation allowance - end of year	$	18,560		$	18,955

At December 31, 2019 and 2018, the Company established a full valuation allowance on: (1) operating loss carryforwards relating to operations in Singapore; (2) un-utilized foreign tax credits available in Ireland and (3) certain other deferred tax assets related to branch operations. At December 31, 2019, the valuation allowance on certain unrealized investment losses was released as the Company was in an unrealized investment gain position.

Although realization is not assured, management believes it is more likely than not that the tax benefit of the recorded net deferred tax assets will be realized. In evaluating the Company's ability to recover these tax assets within the jurisdiction from which they arise, it considered all available positive and negative evidence, including historical results, operating loss carry-back potential and scheduled reversals of deferred tax liabilities. The Company believes its U.S. and U.K. operations

will produce significant taxable income in future periods and have deferred tax liabilities that will reverse in future periods, such that the Company believes sufficient ordinary taxable income is available to utilize all remaining ordinary deferred tax assets.

The following table presents the distribution of income before income taxes between domestic and foreign jurisdictions as well as a reconciliation of the actual income tax rate to the amount computed by applying the effective tax rate of 0% under Bermuda law to income before income taxes:




Year ended December 31,	2019			2018			2017

Income (loss) before income taxes
Bermuda (domestic)	$	179,418		$	181,597		$	(188,420	)
Foreign	167,747			(168,062		)	(188,091		)
Total income (loss) before income taxes	$	347,165		$	13,535		$	(376,511	)

Reconciliation of effective tax rate (% of income before income taxes)
Expected tax rate	0.0		%	0.0		%	0.0		%
Foreign taxes at local expected rates:
U.S.	8.1		%	65.7		%	6.6		%
Europe	0.4		%	(289.7		)%	5.8		%
Other	—		%	0.0		%	0.3		%
Valuation allowance	1.3		%	(13.4		)%	—		%
Net tax exempt income	—		%	(3.3		)%	0.1		%
Change in U.S. enacted tax rate	—		%	0.0		%	(11.1		)%
Change in European enacted tax rate	—		%	16.9		%	—		%
Other	(3.0		)%	5.9		%	0.3		%
Actual tax rate	6.8		%	(217.9		)%	2.0		%