

	2019					2018					2017
	Amount			% of EBT		Amount			% of EBT		Amount			% of EBT
Earnings before income taxes (“EBT”)	$	1,108				$	639				$	724

Income taxes at statutory rate	$	233		21	%	$	134		21	%	$	253		35	%
Effect of:
Tax exempt interest	(14		)	(1	%)	(13		)	(2	%)	(23		)	(3	%)
Stock-based compensation	(8		)	(1	%)	(8		)	(1	%)	(16		)	(2	%)
Dividend received deduction	(4		)	—	%	(4		)	(1	%)	(8		)	(1	%)
Adjustment to prior year taxes	(3		)	—	%	(8		)	(1	%)	(4		)	(1	%)
Employee stock ownership plan dividend paid deduction	(2		)	—	%	(3		)	(1	%)	(5		)	(1	%)
Change in valuation allowance (excluding change in tax rate)	17			2	%	11			2	%	(7		)	(1	%)
Nondeductible expenses	8			1	%	7			1	%	6			1	%
Foreign operations	4			—	%	(2		)	—	%	21			3	%
Neon restructuring	—			—	%	—			—	%	(56		)	(8	%)
Change in U.S corporate tax rate	—			—	%	—			—	%	83			11	%
Other	8			—	%	8			1	%	3			1	%
Provision for income taxes as shown in the statement of earnings	$	239		22	%	$	122		19	%	$	247		34	%

In January 2008, AFG paid $75 million in cash to acquire approximately 67% of Neon Underwriting Limited (“Neon”, formerly known as Marketform Group Limited), a United Kingdom-based Lloyd’s insurer. During 2012, AFG acquired the then-remaining shares of Neon that it did not already own for $17 million. AFG’s investment in Neon includes the cost of acquiring the company as well as additional capital provided to Neon since the date of acquisition.

In 2011, cumulative losses at Neon across multiple lines of business resulted in uncertainty concerning the realization of the deferred tax benefits associated with the losses. Consequently, AFG began maintaining a full valuation allowance against the deferred tax assets related to the Lloyd’s insurance business in 2011.

Approximately $14 million of the $21 million impact of “foreign operations” for 2017 in the table above relates to a reduction in the “foreign underwriting losses” deferred tax asset as a result of the sale of the noncontrolling interest in Neon. Since AFG maintains a full valuation allowance against the deferred tax assets related to Neon, this reduction in deferred tax assets was offset by a corresponding reduction in the valuation allowance and had no overall impact on AFG’s income tax expense or results of operations.

The changes in valuation allowance in the table above are primarily increases in the valuation allowance on tax benefits related to losses in the Neon Lloyd’s insurance business. The $61 million decrease in the valuation allowance in 2017 related to the change in the U.S. corporate tax rate is included in “Change in U.S. corporate tax rate” in table above.

The sale of the noncontrolling interest in Neon in the fourth quarter of 2017 resulted in the recognition of a tax benefit of $56 million, including the recognition of a deferred loss from the 2016 restructuring of Neon. Approximately $20 million of the $56 million tax benefit recorded in 2017 reduced current taxes payable for 2017. The majority of the remaining 2017

The Tax Cuts and Jobs Act of 2017 (“TCJA”), which was enacted on December 22, 2017, lowered the U.S corporate tax rate to 21% and made other widespread changes to the U.S. tax code effective in 2018. Because the TCJA was enacted in December 2017, AFG recorded the $83 million decrease in its net deferred tax asset resulting from the changes in the tax code (primarily the lower corporate tax rate applicable to 2018 and future years) in the fourth quarter of 2017.

In addition to the lower U.S. corporate tax rate, the TCJA implemented a new global minimum tax on income earned by foreign subsidiaries of U.S.-based entities known as the Global Intangible Low-taxed Income (“GILTI”) provision. Since almost all of AFG’s earnings are taxable based on U.S. tax rates, the GILTI is not expected to be material to AFG’s results of operations and will be recorded in the period that any tax arises.

At the time it was enacted, the TCJA was subject to further clarification and interpretation by the U.S. Treasury Department and the Internal Revenue Service. AFG’s deferred tax assets and liabilities were recorded at December 31, 2017 using reasonable estimates based on available information and were considered provisional in accordance with Securities and Exchange Commission Staff Accounting Bulletin No. 118 (“SAB 118”). In accordance with SAB 118, changes in deferred taxes resulting from clarification and interpretation of the TCJA were recorded in 2018 in the period in which the guidance was published and did not have a material impact on AFG’s effective tax rate. As a result, AFG’s implementation of the TCJA was complete as of December 31, 2018.



	2019			2018			2017
Current taxes:
Federal	$	250		$	196		$	153
State	10			8			6
Foreign	2			—			—
Deferred taxes:
Federal	(23		)	(82		)	5
Impact of change in U.S. corporate tax rate	—			—			83
Total Federal deferred taxes	(23		)	(82		)	88
Provision for income taxes	$	239		$	122		$	247

Deferred income tax assets and liabilities reflect temporary differences between the carrying amounts of assets and liabilities recognized for financial reporting purposes and the amounts recognized for tax purposes. The significant components of deferred tax assets and liabilities included in AFG’s Balance Sheet at December 31 were as follows (in millions):



	2019									2018
	Excluding Unrealized Gains			Impact of Unrealized Gains			Total			Excluding Unrealized Gains			Impact of Unrealized Gains			Total
Deferred tax assets:
Federal net operating loss carryforwards	$	19		$	—		$	19		$	23		$	—		$	23
Foreign underwriting losses	118			—			118			93			—			93
Insurance claims and reserves	829			46			875			740			3			743
Employee benefits	93			—			93			88			—			88
Other, net	45			(2		)	43			44			—			44
Total deferred tax assets before valuation allowance	1,104			44			1,148			988			3			991
Valuation allowance against deferred tax assets	(140		)	—			(140		)	(119		)	—			(119		)
Total deferred tax assets	964			44			1,008			869			3			872
Deferred tax liabilities:
Investment securities	(140		)	(416		)	(556		)	(36		)	(34		)	(70		)
Deferred policy acquisition costs	(293		)	143			(150		)	(300		)	9			(291		)
Insurance claims and reserves transition liability	(93		)	—			(93		)	(110		)	—			(110		)
Real estate, property and equipment	(35		)	—			(35		)	(36		)	—			(36		)
Total deferred tax liabilities	(561		)	(273		)	(834		)	(482		)	(25		)	(507		)
Net deferred tax asset (liability)	$	403		$	(229	)	$	174		$	387		$	(22	)	$	365

AFG’s net deferred tax asset at December 31, 2019 and 2018 is included in other assets in AFG’s Balance Sheet. The decrease in AFG’s net deferred tax asset at December 31, 2019 compared to December 31, 2018 reflects significantly higher pretax unrealized gains on securities.

“Foreign underwriting losses” in the table above is primarily the net operating loss carryforward and other deferred tax assets related to the Neon Lloyd’s insurance business. Due to uncertainty concerning the realization of the deferred tax benefits associated with these losses, AFG maintains a full valuation allowance of $118 million against these deferred tax assets at December 31, 2019. In addition to the valuation allowance related to the Neon Lloyd’s insurance business, the gross deferred tax asset has also been reduced by a $19 million valuation allowance related to AFG’s net operating loss carryforwards (“NOL”) subject to the separate return limitation year (“SRLY”) tax rules. A SRLY NOL can be used only by the entity that created it and only in years that both it and the consolidated group have taxable income. Approximately $19 million of AFG’s SRLY NOLs expired unutilized at December 31, 2019. Since AFG maintains a full valuation allowance against its SRLY NOLs, the expiration of these loss carryforwards was offset by corresponding reduction in the valuation allowance and had no overall impact on AFG’s income tax expense or results of operations.

AFG increased its liability for uncertain tax positions by $1 million in 2015 due to uncertainty in state taxation of its surplus lines insurance subsidiaries. In 2017, this uncertainty was resolved, resulting in total tax payments of less than $1 million.

A progression of the liability for uncertain tax positions, excluding interest and penalties, follows (in millions):



	2019		2018		2017
Balance at January 1	$	—	$	—	$	1
Additions for tax positions of prior years	—		—		—
Reductions for tax positions of prior years	—		—		—
Additions for tax positions of current year	—		—		—
Settlements	—		—		(1		)
Balance at December 31	$	—	$	—	$	—

At December 31, 2019, there are no unrecognized tax benefits and related interest and penalties that, if recognized, would impact the effective tax rate. The total unrecognized tax benefits and related interest and penalties that, if recognized, would impact the effective tax rate was less than $1 million at December 31, 2018. There is no interest expense related to unrecognized tax benefits included in AFG’s provision for income taxes in 2019; AFG’s provision for income taxes in 2018 and 2017 included interest expense related to unrecognized tax benefits of less than $1 million in each year (net of federal benefit or expense). There is no liability for interest related to unrecognized tax benefits at December 31, 2019 or December 31, 2018. AFG’s provision for income taxes in 2019, 2018 and 2017 included penalties of less than $1 million in each year. There is no liability for penalties related to unrecognized tax benefits at December 31, 2019; AFG’s liability for penalties related to unrecognized tax benefits was less than $1 million at December 31, 2018.