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INCOME TAXES
9 Months Ended
Sep. 30, 2024
Income Tax Disclosure [Abstract]  
INCOME TAXES INCOME TAXES
On December 27, 2023, the Government of Bermuda enacted the Corporate Income Tax Act 2023 (the "Act") which will apply a corporate income tax of 15% for fiscal years beginning on or after January 1, 2025. The Act includes a provision referred to as the economic transition adjustment, which is intended to provide a fair and equitable transition into the tax regime. Pursuant to the Act and subsequently issued guidance, the Company recorded a net deferred tax asset of $nil and $163 million for the three and nine months ended September 30, 2024 which it expects to utilize mainly over a 10-year period. The Company expects to incur increased taxes in Bermuda beginning in 2025.

The following tables provide an analysis of income tax expense (benefit):
Three months ended September 30,20242023
Current income tax expense (benefit)
U.S.$25,451 $17,879 
Europe9,558 (1,105)
Bermuda
2,486 92 
Deferred income tax expense (benefit)
U.S.4,380 (4,209)
Europe6,047 11,967 
Bermuda
 — 
Total income tax expense (benefit)$47,922 $24,624 

Nine months ended September 30,20242023
Current income tax expense (benefit)
U.S.$76,744 $52,262 
Europe19,488 7,415 
Bermuda
2,486 291 
Deferred income tax expense (benefit)
U.S.2,120 (14,854)
Europe25,682 22,964 
Bermuda
(162,705)— 
Total income tax expense (benefit)$(36,185)$68,078 
The following tables present the distribution of income before income taxes between domestic and foreign jurisdictions and 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:
Three months ended September 30,20242023
Income before income taxes
Bermuda (domestic)$6,695$98,388
Foreign221,955114,334
 Total income before income taxes$228,650$212,722
Reconciliation of effective tax rate (% of income before income taxes)
Expected tax rate0.0 %0.0 %
Foreign taxes at local expected rates:
U.S.12.7 %6.7 %
Europe7.3 %5.1 %
Valuation allowance(2.8 %)(3.5 %)
Bermuda Economic Transition Adjustment
0.0 %0.0 %
Other3.8 %3.3 %
Actual tax rate21.0 %11.6 %

Nine months ended September 30,20242023
Income before income taxes
Bermuda (domestic)$154,014$262,770
Foreign597,954324,178
 Total income before income taxes$751,968$586,948
Reconciliation of effective tax rate (% of income before income taxes)
Expected tax rate0.0 %0.0 %
Foreign taxes at local expected rates:
U.S.10.4 %6.4 %
Europe6.0 %5.2 %
Valuation allowance(1.2 %)(1.8 %)
Bermuda Economic Transition Adjustment(21.6 %)0.0 %
Other1.6 %1.8 %
Actual tax rate(4.8 %)11.6 %