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Provision for Taxes
12 Months Ended
Mar. 31, 2024
Disclosure Text Block [Abstract]  
Provision for Taxes

Note 15. Provision for Taxes

Earnings before taxes and the provision for taxes consisted of the following:

 

 

 

Years Ended March 31,

 

 

 

2024

 

 

2023

 

 

2022

 

 

 

(In thousands)

 

Pretax earnings:

 

 

 

 

U.S.

$

 

816,238

 

$

 

1,179,738

 

$

 

1,432,231

 

Non-U.S.

 

23,939

 

 

 

39,659

 

 

 

44,342

 

Total pretax earnings

$

 

840,177

 

$

 

1,219,397

 

$

 

1,476,573

 

 

 

 

 

 

 

 

 

 

 

Current provision

 

 

 

 

 

 

 

 

 

Federal

$

 

66,356

 

$

 

115,171

 

$

 

189,488

 

State

 

 

44,707

 

 

 

42,121

 

 

 

55,518

 

Non-U.S.

 

 

254

 

 

 

5,150

 

 

 

6,893

 

 

 

 

111,317

 

 

 

162,442

 

 

 

251,899

 

Deferred provision

 

 

 

 

 

 

 

 

 

Federal

 

 

88,549

 

 

 

114,355

 

 

 

90,852

 

State

 

 

6,542

 

 

 

14,077

 

 

 

6,355

 

Non-U.S.

 

 

5,062

 

 

 

4,051

 

 

 

3,105

 

 

 

 

100,153

 

 

 

132,483

 

 

 

100,312

 

 

 

 

 

 

 

 

 

 

 

Provision for income tax expense

$

 

211,470

 

$

 

294,925

 

$

 

352,211

 

 

 

 

 

 

 

 

 

 

 

Income taxes paid (received)

$

 

68,623

 

$

 

145,680

 

$

 

(4,548

)

 

The difference between the tax provision at the statutory federal income tax rate and the tax provision attributable to income before taxes was as follows:

 

 

 

Years Ended March 31,

 

 

 

 

2024

 

 

2023

 

 

2022

 

 

 

 

(In percentages)

 

 

Statutory federal income tax rate

 

21.00

 

%

 

21.00

 

%

 

21.00

 

%

Increase (reduction) in rate resulting from:

 

 

 

 

 

 

 

 

 

 

State taxes, net of federal benefit

 

 

4.78

 

%

 

3.56

 

%

 

3.24

 

%

Foreign rate differential

 

 

0.03

 

%

 

0.08

 

%

 

0.05

 

%

Federal tax credits

 

 

(0.58

)

%

 

(0.48

)

%

 

(0.19

)

%

Tax-exempt income

 

 

(0.04

)

%

 

(0.08

)

%

 

(0.03

)

%

Dividend received deduction

 

 

(0.01

)

%

 

(0.01

)

%

 

 

%

Other

 

 

(0.01

)

%

 

0.15

 

%

 

(0.22

)

%

Effective income tax rate

 

 

25.17

 

%

 

24.22

 

%

 

23.85

 

%

 

Significant components of our deferred tax assets and liabilities were as follows:

 

 

 

March 31,

 

 

 

2024

 

 

2023

 

Deferred tax assets:

 

(In thousands)

 

Benefit of tax net operating loss, interest and credit carryforwards

$

 

36,978

 

$

 

33,778

 

Accrued expenses

 

 

117,481

 

 

 

112,971

 

Policy benefit and losses, claims and loss expenses payable, net

 

 

33,736

 

 

 

36,374

 

Unrealized losses on investments

 

 

32,856

 

 

 

48,179

 

Operating leases

 

 

11,521

 

 

 

12,058

 

Total deferred tax assets

$

 

232,572

 

$

 

243,360

 

 

 

 

 

 

 

 

Deferred tax liabilities:

 

 

 

 

 

 

Property, plant and equipment

$

 

1,655,074

 

$

 

1,545,628

 

Operating leases

 

 

11,214

 

 

 

12,175

 

Deferred policy acquisition costs

 

 

10,709

 

 

 

12,038

 

Other

 

 

2,700

 

 

 

3,008

 

Total deferred tax liabilities

 

 

1,679,697

 

 

 

1,572,849

 

Net deferred tax liability

$

 

1,447,125

 

$

 

1,329,489

 

 

The NOL, interest and credit carry-forwards in the above table are primarily attributable to state NOLs. As of March 31, 2024 and 2023, we had state NOLs of $628.9 million and $480.0 million, respectively, that will expire between fiscal 2025 and 2044 for most jurisdictions, if not utilized.

On March 3, 2021, the IRS notified us that our federal income tax returns for the tax years March 31, 2014, 2015, 2016, 2018 and 2019 were selected for examination. The examination eventually expanded to include all years March 31, 2012 through March 31, 2021. The examination was completed and report finalized in March 2024. As a result, we are owed $129 million, plus interest of $11.4 million, both of which are reflected in prepaid expense.

No additional income taxes have been provided for any remaining undistributed foreign earnings not subject to transition tax, or any additional outside basis difference inherent in these entities, as these amounts continue to be indefinitely reinvested in foreign operations. Determining the amount of unrecognized deferred tax liability related to any remaining undistributed foreign earnings not subject to the transition tax and additional outside basis difference in these entities (i.e., basis difference in excess of that subject to the one-time transition tax) is not practicable.

We account for uncertainty in income taxes by recognizing the tax benefit or expense from an uncertain tax position only if it is more likely than not that the tax position will be sustained upon examination by the taxing authorities, based on the technical merits of the position. The Company measures the tax benefits and expenses recognized in the consolidated financial statements from such a position based on the largest benefit that has a greater than 50% likelihood of being realized upon ultimate resolution.

A reconciliation of the total amounts of unrecognized tax benefits at the beginning and end of the period are as follows:

 

 

 

Unrecognized Tax Benefits

 

 

 

March 31,

 

 

 

2024

 

 

2023

 

 

 

(In thousands)

 

 

 

 

 

 

 

 

Unrecognized tax benefits beginning balance

$

 

58,107

 

$

 

48,851

 

Additions based on tax positions related to the current year

 

 

10,202

 

 

 

7,226

 

Reductions for tax positions of prior years

 

 

(27,536

)

 

 

(443

)

Additions for tax provisions of prior years

 

 

41,203

 

 

 

2,473

 

Unrecognized tax benefits ending balance

$

 

81,976

 

$

 

58,107

 

 

Included in the balance of unrecognized tax benefits as of March 31, 2024 and March 31, 2023 are $64.8 million and $45.9 million, respectively, of tax benefits that, if recognized, would affect the effective tax rate.

We recognize interest related to unrecognized tax benefits and penalties as income tax expenses. As of March 31, 2024 and 2023, the amount of interest accrued on unrecognized tax benefits was $9.6 million and $17.7 million, respectively, net of tax. During the current year, we recorded a benefit from interest in the amount of $8.1 million, net of tax. At March 31, 2024 and 2023, the amount of penalties accrued on unrecognized tax benefits was $20.2 million and $12.2 million. During the current year, we recorded expense from penalties in the amount of $8.0 million. We do not expect the total amount of unrecognized tax benefits to significantly increase or decrease within 12 months of the reporting date.

We file income tax returns in the U.S. federal jurisdiction, and various states and Canadian jurisdictions. While the Company has ongoing audits in Canada and various state jurisdictions, there have been no proposed or anticipated adjustments that would materially impact the consolidated financial statements. Our tax years remain open for examination by federal authorities for three years, state authorities for three to four years and Canadian authorities for four years.

The Canadian government has issued draft Pillar Two legislation (Global Minimum Tax Act), including the Income Inclusion Rule and Qualified Domestic Minimum Top-Up Tax, which it intends to enact in 2024. The Canadian legislation is expected to be effective for our fiscal year beginning April 1, 2024. We have performed an assessment of the potential exposure to Pillar Two income taxes. Based on the assessment performed, the Pillar Two effective tax rates in all jurisdictions in which we operate are above the 15% minimum tax rate. We will continue to evaluate the legislation but do not expect the rules to have an impact on the income tax provision or cash taxes.

The Inflation Reduction Act of 2022 (the “IRA”) includes a 15% corporate alternative minimum tax on certain large corporations and a 1% excise tax on certain corporate stock repurchases. The impact on the Company of these provisions, which became effective on January 1, 2023, will depend on several factors, including recently released and forthcoming interpretive regulatory guidance. The Company continues to review and assess the provisions of the IRA but does not current expect it to materially impact the consolidated financial statements.