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Income Taxes (Tables)

9 Months Ended

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)
Deferred 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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