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Income Taxes (Tables)
12 Months Ended
Dec. 31, 2022
Income Tax Disclosure [Abstract]  
Components of income taxes attributable to operations
The components of income taxes attributable to operations were as follows:
Year Ended December 31,
202220212020
Current expense (benefit):
United States$195,588 $284,274 $181,571 
Non-U.S.5,628 11,259 16,091 
201,216 295,533 197,662 
Deferred expense (benefit):
United States(96,599)(123,261)(89,170)
Non-U.S.(24,656)(43,690)3,346 
(121,255)(166,951)(85,824)
Income tax expense$79,961 $128,582 $111,838 
Schedule of income or loss before income taxes by jurisdiction
The Company’s income or loss before income taxes was earned in the following jurisdictions:
Year Ended December 31,
202220212020
Income (Loss) Before Income Taxes:
Bermuda$985,828 $1,518,616 $1,114,117 
United States400,865 643,239 409,893 
Other175,691 206,187 53,539 
Total$1,562,384 $2,368,042 $1,577,549 
Reconciliation of the differences between the provision for income taxes and the expected tax provision at the weighted average tax rate
A reconciliation of the difference between the provision for income taxes and the expected tax provision at the weighted average tax rate follows:
Year Ended December 31,
202220212020
Expected income tax expense (benefit) computed on pre-tax income at weighted average income tax rate$110,337 $158,269 $111,947 
Addition (reduction) in income tax expense (benefit) resulting from:
Investment income(12,762)(23,572)(1,824)
State taxes, net of U.S. federal tax benefit10,650 20,978 5,027 
Dividend withholding taxes10,559 12,211 7,105 
Change in valuation allowance(22,726)(40,425)13,190 
Base eroding tax7,694 — — 
Share based compensation(9,159)(5,339)(2,533)
Tax credits(9,736)— — 
Intercompany loan write-off(3,544)— (22,083)
Other(1,352)6,460 1,009 
Income tax expense (benefit)$79,961 $128,582 $111,838 
Significant components of deferred income tax assets and liabilities
Significant components of the Company’s deferred income tax assets and liabilities were as follows:
December 31,
20222021
Deferred income tax assets:
Net operating loss$76,665 $87,960 
Discounting of net loss reserves77,556 72,001 
Net unearned premium reserve96,581 75,483 
Compensation liabilities55,269 28,062 
Foreign tax credit carryforward16,738 20,058 
Bad debt reserves17,365 10,252 
Depreciation and amortization141,409 115,041 
Lease liability26,681 21,453 
Net unrealized decline of investments192,949 — 
Lloyds year of account deferral1,385 — 
Other, net14,450 703 
Deferred tax assets before valuation allowance717,048 431,013 
Valuation allowance(6,968)(43,953)
Deferred tax assets net of valuation allowance710,080 387,060 
Deferred income tax liabilities:
Deposit accounting liability(2,658)(1,578)
Goodwill and intangibles(38,905)(70,549)
Lloyds year of account deferral— (12,514)
Contingency reserve(43,870)(49,486)
Deferred policy acquisition costs(63,708)(25,612)
Investment related(9,225)(7,492)
Net unrealized appreciation of investments— (8,377)
Right-of-use asset(20,781)(17,406)
Total deferred tax liabilities(179,147)(193,014)
Net deferred income tax assets$530,933 $194,046 
Summary of operating loss carryforwards
At December 31, 2022, the Company’s net operating loss carryforwards and tax credits were as follows:
Year Ended December 31,
2022
Expiration
Operating Loss Carryforwards
United Kingdom$198,571 No expiration
Ireland61,685 No expiration
Australia32,333 No expiration
Hong Kong28,080 No expiration
Netherlands60 No expiration
United States (1)23,766 
2029 - 2038
Tax Credits
U.K. foreign tax credits13,907 No expiration
U.S. foreign tax credits2,830 2029 - 2032
(1) On January 30, 2014, the Company’s U.S. mortgage operations underwent an ownership change for U.S. federal income tax purposes as a result of the Company’s acquisition of the CMG Entities. As a result of this ownership change, a limitation has been imposed upon the utilization of approximately $7.0 million of the Company’s existing U.S. net operating loss carryforwards. Utilization is limited to approximately $0.6 million per year in accordance with Section 382 of the Internal Revenue Code of 1986 as amended (“the Code”).
Summary of tax credit carryforwards
At December 31, 2022, the Company’s net operating loss carryforwards and tax credits were as follows:
Year Ended December 31,
2022
Expiration
Operating Loss Carryforwards
United Kingdom$198,571 No expiration
Ireland61,685 No expiration
Australia32,333 No expiration
Hong Kong28,080 No expiration
Netherlands60 No expiration
United States (1)23,766 
2029 - 2038
Tax Credits
U.K. foreign tax credits13,907 No expiration
U.S. foreign tax credits2,830 2029 - 2032
(1) On January 30, 2014, the Company’s U.S. mortgage operations underwent an ownership change for U.S. federal income tax purposes as a result of the Company’s acquisition of the CMG Entities. As a result of this ownership change, a limitation has been imposed upon the utilization of approximately $7.0 million of the Company’s existing U.S. net operating loss carryforwards. Utilization is limited to approximately $0.6 million per year in accordance with Section 382 of the Internal Revenue Code of 1986 as amended (“the Code”).
Reconciliation of the beginning and ending amount of unrecognized tax benefits A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows:
December 31,
20222021
Balance at beginning of year$2,008 $2,008 
Additions based on tax positions related to the current year— — 
Additions for tax positions of prior years— — 
Reductions for tax positions of prior years— — 
Settlements— — 
Balance at end of year$2,008 $2,008 
Summary of open tax years potentially subject to examination, by jurisdiction The following table details open tax years that are potentially subject to examination by local tax authorities, in the following major jurisdictions:
JurisdictionTax Years
United States
2015-2022
United Kingdom
2020-2022
Ireland
2018-2022
Canada
2018-2022
Switzerland
2018-2022
Denmark
2018-2022
Australia
2018-2022