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Income Taxes (Tables) | 9 Months Ended
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Sep. 30, 2024
Income Tax Disclosure [Abstract] |
Summary of Total Income Tax | Total income tax (benefit)/expense for the twelve months ended December 31, 2023, 2022 and 2021 was allocated as follows:
| Twelve Months Ended December 31,
| 2023 |  | 2022 |  | 2021
| ($ in millions)
Income tax (benefit)/expense allocated to net income | $ | (132.1) |  |  | $ | (78.1) |  |  | $ | 5.3 |
Income tax expense/(benefit) allocated to other comprehensive income | 20.6 |  |  | (23.9) |  |  | 0.3 |
Total income tax (benefit)/expense | $ | (111.5) |  |  | $ | (102.0) |  |  | $ | 5.6 |
Schedule of Income Tax by Taxing Authority | Income/(loss) from operations before income taxes and income tax expense/(benefit) attributable to that income/(loss) for the twelve months ended December 31, 2023, 2022 and 2021 is provided in the tables below:
| Twelve Months Ended December 31, 2023
| Income before tax |  | Current tax expense |  | Deferred tax (benefit)/expense |  | Total income tax (benefit)/expense
| ($ in millions)
Bermuda (1) | $ | 148.8 |  |  | $ | — |  |  | $ | (201.1) |  |  | $ | (201.1) |
U.S. (2) | 236.3 |  |  | 52.4 |  |  | 3.0 |  |  | 55.4 |
U.K. (3) | 0.7 |  |  | 5.3 |  |  | 0.1 |  |  | 5.4 |
Other (4) | 16.8 |  |  | 7.9 |  |  | 0.3 |  |  | 8.2 |
Total | $ | 402.6 |  |  | $ | 65.6 |  |  | $ | (197.7) |  |  | $ | (132.1) |
| Twelve Months Ended December 31, 2022
| (Loss)/income before tax |  | Current tax expense |  | Deferred tax (benefit) |  | Total income tax (benefit)/expense
| ($ in millions)
Bermuda | $ | (103.3) |  |  | $ | — |  |  | $ | — |  |  | $ | — |
U.S. | 34.8 |  |  | 14.8 |  |  | (102.9) |  |  | (88.1) |
U.K. | 62.4 |  |  | 7.0 |  |  | — |  |  | 7.0 |
Other | (20.9) |  |  | 4.7 |  |  | (1.7) |  |  | 3.0 |
Total | $ | (27.0) |  |  | $ | 26.5 |  |  | $ | (104.6) |  |  | $ | (78.1) |
| Twelve Months Ended December 31, 2021
| Income/(loss) before tax |  | Current tax expense |  | Deferred tax (benefit) |  | Total income tax expense/(benefit)
| ($ in millions)
Bermuda | $ | 22.9 |  |  | $ | — |  |  | $ | — |  |  | $ | — |
U.S | 5.0 |  |  | 5.8 |  |  | — |  |  | 5.8 |
U.K. | 75.1 |  |  | — |  |  | (0.3) |  |  | (0.3) |
Other | (67.9) |  |  | 2.7 |  |  | (2.9) |  |  | (0.2) |
Total | $ | 35.1 |  |  | $ | 8.5 |  |  | $ | (3.2) |  |  | $ | 5.3 |
Income Tax Reconciliation | The reconciliation between the income tax (benefit)/expense and the amount that would result from applying the statutory rate for the Company for the twelve months ended December 31, 2023, 2022 and 2021 is provided in the table below:
| Twelve Months Ended December 31,
| 2023 |  | 2022 |  | 2021
Income Tax Reconciliation | ($ in millions)
Income tax benefit at statutory tax rate of zero percent | $ | — |  |  | $ | — |  |  | $ | — |
Overseas statutory tax rates differential | 56.3 |  |  | 16.8 |  |  | (0.9) |
Base erosion and anti-abuse tax (BEAT) expense | 0.9 |  |  | 2.3 |  |  | 6.1 |
Prior year adjustments (1) | 6.9 |  |  | (2.9) |  |  | 0.5 |
Introduction of Bermuda corporate income tax | (201.1) |  |  | — |  |  | — |
Change in valuation allowance (2) | 4.0 |  |  | (98.9) |  |  | 9.6 |
Impact of unrecognized tax benefits (3) | — |  |  | — |  |  | — |
Australian non-resident withholding tax | — |  |  | 1.5 |  |  | 0.6 |
Foreign exchange | (1.3) |  |  | (0.3) |  |  | (1.5) |
Non-deductible expenses | 2.5 |  |  | 2.4 |  |  | 2.4 |
Impact of changes in statutory tax rates | (0.3) |  |  | (5.7) |  |  | (11.5) |
Tax effect of OCI in income statement | — |  |  | 6.7 |  |  | — |
Total income tax (benefit)/expense | $ | (132.1) |  |  | $ | (78.1) |  |  | $ | 5.3 |
________________ (1)The submission dates for filing income tax returns for the Company’s U.S. and U.K. operating subsidiaries are after the submission date of this report. Accordingly, the final tax liabilities may differ from the estimated income tax expense included in this report and may result in prior year adjustments being reported. The prior period adjustments for the twelve months ended December 31, 2023 predominantly relate to the determination of the results of the branches of the U.K. operating subsidiaries. The prior period adjustments for the twelve months ended December 31, 2022 and 2021 predominantly relate to the determination of results in the U.K. (2)The decrease in valuation allowance in 2022 related to a change in judgment about the recoverability of deferred tax assets in the U.S. operating subsidiaries. (3)In 2023, the Company did not have any unrecognized tax benefits.
Tax Effects of Deferred Tax Assets and Deferred Tax Liabilities | The tax effects of temporary differences and carryforwards that give rise to deferred tax assets and deferred tax liabilities are presented in the following table as at December 31, 2023 and 2022:
| As at December 31,
| 2023 |  | 2022
| ($ in millions)
D eferred tax assets: |  |  |
Operating loss carryforwards | 217.2 |  |  | 167.6 |
Capital loss carryforwards | 9.7 |  |  | 6.7 |
Insurance reserves: Losses and loss adjustment expenses | 104.1 |  |  | 28.3 |
Unrealized losses on investments | 8.9 |  |  | 20.6 |
Accrued expenses | 13.4 |  |  | 6.1 |
Foreign tax credit carryforwards | 19.0 |  |  | 19.8 |
Insurance reserves: Unearned premiums | 35.0 |  |  | 36.0 |
Intangible assets | 82.9 |  |  | 0.7 |
Office properties and equipment | 16.5 |  |  | 14.2 |
Operating lease liabilities | 15.6 |  |  | 18.5 |
Other temporary differences | 7.6 |  |  | 3.7 |
Total deferred tax assets | 529.9 |  |  | 322.2 |
Less valuation allowance | (172.7) |  |  | (145.7) |
Deferred tax assets, net of valuation allowance | $ | 357.2 |  |  | $ | 176.5 |
Deferred tax liabilities: |  |  |
Deferred acquisition costs | (32.4) |  |  | (37.0) |
Right-of-use operating lease assets | (10.4) |  |  | (13.7) |
Insurance reserves: Losses and loss adjustment expenses | (0.1) |  |  | (0.2) |
Other temporary differences | (3.3) |  |  | (6.4) |
Total deferred tax (liabilities) | (46.2) |  |  | (57.3) |
Net deferred tax assets | $ | 311.0 |  |  | $ | 119.2 |

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