INCOME TAXES

Ambac files a consolidated Federal income tax return with its subsidiaries. Ambac and its subsidiaries also file separate or combined income tax returns in various states, local and foreign jurisdictions. The following are the major jurisdictions in which Ambac and its affiliates operate and the earliest tax years subject to examination:



Jurisdiction	Tax Year
United States	2010
New York State	2008
New York City	2011
United Kingdom	2006
Italy	2007

As of March 31, 2014 Ambac had loss carryforwards totaling $6,079,936. This includes carryforwards of $577,742 relating to U.S. capital losses, $306,769 of Ambac UK loss carryforwards, and an ordinary U. S. federal net operating tax carryforward of approximately $5,195,425, which, if not utilized, will begin expiring in 2029, and will fully expire in 2034.

The tax effects of temporary differences that give rise to significant portions of the deferred tax liabilities and deferred tax assets at March 31, 2014 and December 31, 2013 are presented below:



	Successor Ambac
	March 31, 2014			December 31, 2013
Deferred tax liabilities:
Insurance intangible	$	549,525		$	559,288
Variable interest entities	127,399			131,137
Investments	180,607			168,653
Unearned premiums and credit fees	45,265			38,826
Other	2,224			2,221
Total deferred tax liabilities	905,020			900,125
Deferred tax assets:
Unrealized losses & impairments on investments	—			—
Net operating loss and capital carryforward	2,127,884			2,177,029
Loss reserves	590,032			634,692
Compensation	9,005			8,724
AMT Credits	6,903			4,269
Other	58,597			58,581
Sub-total deferred tax assets	2,792,421			2,883,295
Valuation allowance	1,889,603			1,985,369
Total deferred tax assets	902,818			897,926
Net deferred tax liability	$	(2,202	)	$	(2,199	)

In accordance with the Income Tax Topic of the ASC, a valuation allowance is recognized if, based on the weight of available evidence, it is more-likely-than-not that some or all of the deferred tax asset will not be realized. Recent cumulative losses are a significant piece of negative evidence in assessing whether a valuation allowance is required. As a result of Ambac’s history of operating losses as well as the risks and uncertainties associated with future operating results, management believes it is more likely than not that the Company will not generate sufficient taxable income to recover the deferred tax operating asset and therefore has a full valuation allowance.