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Income Taxes
9 Months Ended
Sep. 30, 2018
Income Taxes [Abstract]  
Income Taxes

Note 15 Income Taxes

A. Income Tax Expense

The consolidated effective tax rate decreased to 25.5% for the nine months ended September 30, 2018 compared with 31.0% for the nine months ended September 30, 2017. The significantly lower effective tax rate for 2018 was attributable to a lower U.S. tax rate effective January 1, 2018 resulting from U.S. tax reform legislation enacted in 2017. This favorable effect was partially offset by the reinstatement of the non-deductible health insurance industry tax in 2018 and the absence of an incremental tax benefit recognized in the second quarter of 2017 associated with merger-related costs (see Note 3). During the third quarter of 2018, the Company updated its accounting for the provisional amounts first recognized in fourth quarter 2017 as a result of U.S. tax reform legislation by recording a tax benefit of $7 million.

The Company is subject to the global intangible low-taxed income (“GILTI”) provisions of U.S. tax reform that became effective January 1, 2018. Unlike the rate change and the tax on unremitted foreign earnings, the GILTI rules did not trigger any provisional accounting in 2017. However, they are effective prospectively beginning in 2018. Based on our current understanding of these rules, the GILTI tax impact was immaterial for the nine months ended September 30, 2018. Given the complexity of these provisions, further guidance is expected to be released in the fourth quarter of 2018. The Company will evaluate the new guidance upon its release and make a determination of the impact. It is the Company’s policy to recognize any GILTI taxes as period costs when incurred.

The Company’s foreign operations continue to maintain a significant portion of their earnings overseas. These undistributed earnings are deployed outside of the United States predominantly in support of the liquidity and regulatory capital requirements of our foreign operations as well as to support growth initiatives overseas. The Company does not intend to repatriate these earnings to the United States. If the Company had intended to repatriate these foreign earnings to the United States, the Company would have recorded additional deferred tax liabilities of approximately $148 million for foreign withholding taxes as of September 30, 2018. A portion of these taxes may be eligible for credit against the Company’s U.S. tax liability.

B. Unrecognized Tax Benefits

Changes in unrecognized tax benefits were immaterial for the nine months ended September 30, 2018.