Income Tax

12 Months Ended

Dec. 31, 2021

Income Tax Disclosure [Abstract]

Income Tax

INCOME TAX

The effective tax rate for 2021 was lower than the U.S. Statutory rate of 21.0% primarily as a result of the release of uncertain tax positions due to the expiration of the statute of limitations, and the release of valuation allowances primarily due to income earned in RGA Australia. This benefit was partially offset by income earned in jurisdictions with tax rates higher than the U.S. and GILTI, both emerging from income in Canada and Australia. Furthermore, the UK enacted an increase to the statutory tax rate resulting in a tax expense from the remeasurement of the deferred tax liabilities. The effective tax rate for 2020 was higher than the U.S. Statutory rate of 21.0% primarily as a result of income earned in jurisdictions with tax rates higher than the U.S., GILTI tax primarily due to RGA Canada's income, and a change in the corporate tax rate in the UK. These increases were partially offset by foreign tax credit utilization and bases differences in Australia.

Pre-tax income for the years ended December 31, 2021, 2020 and 2019 consists of the following (dollars in millions): 

	2021		2020		2019
Pre-tax income – U.S.	$	327	$	79	$	871
Pre-tax income – foreign	364		474		261
Total pre-tax income	$	691	$	553	$	1,132

The provision for income tax expense for the years ended December 31, 2021, 2020 and 2019 consists of the following (dollars in millions):

	2021		2020		2019
Current income tax expense (benefit):
U.S.	$	91	$	75	$	(9)
Foreign	72		79		60
Total current	163		154		51
Deferred income tax expense (benefit):
U.S.	(127)		(60)		182
Foreign	38		44		29
Total deferred	(89)		(16)		211
Total provision for income taxes	$	74	$	138	$	262

The Company’s effective tax rate differed from the U.S. federal income tax statutory rate of 21% as a result of the following for the years ended December 31, 2021, 2020 and 2019 (dollars in millions):

	2021			2020			2019
Tax provision at U.S. statutory rate	$	145		$	116		$	238
Increase (decrease) in income taxes resulting from:
Tax rate differences on income in other jurisdictions	51			21			2
Differences in tax basis in foreign jurisdictions	(4)			(32)			(23)
Deferred tax valuation allowance	(18)			10			56
Amounts related to uncertain tax positions	(119)			10			8
Equity based compensation	(1)			(1)			(8)
Corporate rate changes	29			13			(1)
GILTI, net of credits	11			13			—
Subpart F for non-full inclusion companies	2			—			1
Foreign tax credits	(10)			(7)			(6)
Return to provision adjustments	(17)			(4)			(6)
Other, net	5			(1)			1
Total provision for income taxes	$	74		$	138		$	262
Effective tax rate (1)	10.6		%	24.9		%	23.1		%

(1)    The Company rounds amounts in the financial statements to millions and calculates the effective tax rate from the underlying whole-dollar amounts. Thus certain amounts may not recalculate based on the numbers due to rounding.

Total income taxes for the years ended December 31, 2021, 2020 and 2019 were as follows (dollars in millions):

	2021		2020		2019
Provision for income taxes	$	74	$	138	$	262
Income tax from OCI and additional paid-in-capital:
Net unrealized holding gain (loss) on debt and equity securities recognized for financial reporting purposes	(520)		611		681
Foreign currency translation	23		(9)		3
Unrealized pension and post retirement	7		(1)		(5)
Total income taxes provided	$	(416)	$	739	$	941

The tax effects of temporary differences that give rise to significant portions of the deferred income tax assets and liabilities at December 31, 2021 and 2020, are presented in the following tables (dollars in millions):

	2021		2020
Deferred income tax assets:
Nondeductible accruals	$	85	$	92
Net operating loss carryforward	251		254
Tax Credit Carryforward	50		—
Other	3		—
Subtotal	389		346
Valuation allowance	(218)		(251)
Total deferred income tax assets	171		95
Deferred income tax liabilities:
Deferred acquisition costs	754		775
Policy reserves and other reinsurance liabilities	1,085		1,105
Invested assets	793		1,043
Outside basis difference foreign subsidiaries	260		354
Foreign currency translation	66		40
Anticipated future tax credit reduction	58		20
Other	—		2
Total deferred income tax liabilities	3,016		3,339
Net deferred income tax liabilities	$	2,845	$	3,244
Balance sheet presentation of net deferred income tax liabilities:
Included in other assets	$	41	$	19
Included in deferred income taxes	2,886		3,263
Net deferred income tax liabilities	$	2,845	$	3,244

As of December 31, 2021, the valuation allowance against deferred tax assets was $218 million. During 2021, there were decreases to the valuation allowance due to pre-tax earnings in certain subsidiaries with valuation allowances. These decreases were partially offset by increases in the valuation allowance due to losses in subsidiaries that do not have a history of income. The valuation allowance was further impacted by changes in foreign currency translation during the year.

As of December 31, 2020, the valuation allowance against deferred tax assets was $251 million. During 2020, there was a $20 million increase to the valuation allowance related to the tax losses of RGA Reinsurance Company of Australia Limited ("RGA Australia"). RGA Australia's tax loss primarily relates to income on internal retrocession that is not taxable in RGA Australia. The RGA Australia deferred tax asset has been reduced to the amount more likely than not to be realized considering the projected future earnings. The valuation allowance increased further due to losses in jurisdictions that do not have a history of income and changes in foreign currency translation during the year. These increases were partially offset by a valuation allowance release related to U.S. Foreign Tax Credit utilization and income in jurisdictions with valuation allowances.

The earnings of substantially all of the Company's foreign subsidiaries have been permanently reinvested in foreign operations. The Company has provided for future tax on the full inclusion companies where the Company cannot assert permanent reinvestment. At December 31, 2021 and 2020, the financial reporting basis in excess of the tax basis for which no deferred taxes have been recognized was approximately $1.8 billion and $2.7 billion, respectively. As U.S. Tax Reform generally eliminates U.S. federal income taxes on dividends from foreign subsidiaries, the Company does not expect to incur material income taxes if these funds were repatriated.

During 2021, 2020, and 2019, the Company received federal and foreign income tax refunds of approximately $20 million, $59 million, and $22 million, respectively. The Company made cash income tax payments of approximately $388 million, $167 million, and $66 million, in 2021, 2020, and 2019, respectively.

The following table presents consolidated net operating losses (“NOL”) as of December 31, 2021 (dollars in millions):

	2021
NOL with no expiration and with no valuation allowance	$	100
NOL with a full valuation allowance	187
NOL with no expiration and a partial valuation allowance	631
NOL with expiration dates between 2025 and 2041 with no valuation allowance	2
Total net operating loss carryforwards	$	920

These net operating losses, other than the net operating losses for which there is a valuation allowance, are expected to be utilized in the normal course of business during the period allowed for carryforwards and in any event, are not expected to be lost, due to the application of tax planning strategies that management would utilize.

As of December 31, 2021, the Company had foreign tax credit carryforwards of $50 million related to the U.S. and Ireland. The Ireland foreign tax credit of $26 million has a full valuation allowance.

The Company files income tax returns in the U.S. federal jurisdiction and various state and foreign jurisdictions. The Company is under continuous examination by the Internal Revenue Service and is subject to audit by taxing authorities in other foreign jurisdictions in which the Company has significant business operations. The income tax years under examination vary by jurisdiction. The Company is no longer subject to U.S. federal income tax examinations by tax authorities for years prior to 2018, Canadian tax authorities for years prior to 2017 and with a few exceptions, the Company is no longer subject to state and foreign income tax examinations by tax authorities for years prior to 2016.

As of December 31, 2021, the Company’s total amount of unrecognized tax benefits is $34 million all of which would affect the effective tax rate, if recognized. Management believes it is reasonably possible that the unrecognized tax benefit could decrease by up to $5 million over the next 12 months if statutes expire.

A reconciliation of the beginning and ending amount of unrecognized tax benefits for the years ended December 31, 2021, 2020 and 2019, is as follows (dollars in millions):

	Total Unrecognized Tax Benefits
	2021		2020		2019
Beginning balance, January 1	$	342	$	333	$	325
Additions for tax positions of prior years	2		281		264
Reductions for tax positions of prior years	(312)		(278)		(262)
Additions for tax positions of current year	2		6		6
Ending balance, December 31	$	34	$	342	$	333

The Company recognized interest expense (benefit) associated with uncertain tax positions in 2021, 2020 and 2019 of $(31) million, $11 million, and $12 million, respectively. As of December 31, 2021 and 2020, the Company had $3 million and $34 million, respectively, of accrued interest related to unrecognized tax benefits. There are no penalties accrued as of December 31, 2021 and 2020.