NOTE 9 Income Taxes

Significant components of the provision for income taxes for the years ended December 31 are as follows:

 

(in millions)

 

2025

 

 

2024

 

 

2023

 

Current:

 

 

 

 

 

 

 

 

 

Federal

 

$

187

 

 

$

198

 

 

$

180

 

State

 

 

68

 

 

 

70

 

 

 

57

 

Foreign

 

 

37

 

 

 

19

 

 

 

23

 

Total current provision

 

 

292

 

 

 

287

 

 

 

260

 

Deferred:

 

 

 

 

 

 

 

 

 

Federal

 

 

38

 

 

 

14

 

 

 

26

 

State

 

 

5

 

 

 

4

 

 

 

6

 

Foreign

 

 

(31

)

 

 

(4

)

 

 

(17

)

Total deferred provision

 

 

12

 

 

 

14

 

 

 

15

 

Total tax provision

 

$

304

 

 

$

301

 

 

$

275

 

 

The table below provides additional information as a result of our adoption of ASU 2023-09. A reconciliation of the differences between the effective tax rate and the federal statutory tax rate for the year ended December 31, 2025 is as follows:

(in millions)

 

2025

 

 

2025

 

Provision for income taxes at U.S. federal statutory rate

 

$

288

 

 

 

21.0

%

Effect of cross-border tax laws

 

 

4

 

 

 

0.2

 

Nontaxable or nondeductible items

 

 

(14

)

 

 

(1.0

)

Other

 

 

(3

)

 

 

(0.2

)

State and local income taxes, net of federal income tax effect

 

 

54

 

 

 

3.9

 

Foreign tax effects

 

 

 

 

 

 

Bermuda

 

 

 

 

 

 

Effect of rates different than statutory

 

 

(24

)

 

 

(1.7

)

Other

 

 

1

 

 

 

0.1

 

Other foreign jurisdictions

 

 

(7

)

 

 

(0.5

)

Worldwide changes in unrecognized tax benefits

 

 

5

 

 

 

0.3

 

Total tax provision and effective tax rate

 

$

304

 

 

 

22.1

%

The individual state and local jurisdictions comprising the majority of state income taxes, net of federal income tax benefit, include: Florida, California, Minnesota, South Carolina, New York City and New Jersey.

As previously disclosed for the years ended December 31, 2024 and 2023, prior to the adoption of ASU 2023-09, a reconciliation of the differences between the effective tax rate and the federal statutory tax rate is as follows:

 

 

 

2024

 

 

2023

 

Federal statutory tax rate

 

 

21.0

%

 

 

21.0

%

State income taxes, net of federal income tax benefit

 

 

4.6

 

 

 

4.5

 

Non-deductible employee stock purchase plan expense

 

 

0.2

 

 

 

0.2

 

Non-deductible meals and entertainment

 

 

0.2

 

 

 

0.2

 

Non-deductible officers’ compensation

 

 

0.4

 

 

 

0.4

 

Tax benefit from stock-based compensation

 

 

(1.9

)

 

 

(1.6

)

Effect of rates different than statutory

 

 

(1.1

)

 

 

 

Other, net

 

 

(0.3

)

 

 

(0.6

)

Effective tax rate

 

 

23.1

%

 

 

24.1

%

Deferred income taxes reflect the net tax effects of temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the corresponding amounts used for income tax reporting purposes.

Significant components of the Company’s net deferred tax liabilities as of December 31 are as follows:

 

(in millions)

 

2025

 

 

2024

 

Non-current deferred tax liabilities:

 

 

 

 

 

 

Intangible assets

 

$

1,355

 

 

$

808

 

Fixed assets

 

 

27

 

 

 

22

 

Right-of-use assets

 

 

61

 

 

 

41

 

Impact of adoption of ASC 606 revenue recognition

 

 

34

 

 

 

31

 

Total non-current deferred tax liabilities

 

 

1,477

 

 

 

902

 

Non-current deferred tax assets:

 

 

 

 

 

 

Deferred compensation

 

 

123

 

 

 

100

 

Accruals and reserves

 

 

60

 

 

 

34

 

Lease liabilities

 

 

70

 

 

 

49

 

Net operating loss carryforwards and other carryforwards

 

 

411

 

 

 

9

 

Valuation allowance for deferred tax assets

 

 

(2

)

 

 

(1

)

Total non-current deferred tax assets

 

 

662

 

 

 

191

 

Net non-current deferred tax liability

 

$

815

 

 

$

711

 

ASU 2023-09 also requires that the Company disclose the amount of income taxes paid, disaggregated by jurisdiction if the income taxes paid to that jurisdiction are greater than or equal to 5% of the total income taxes paid. Income taxes paid in 2025, 2024 and 2023 were $371 million, $304 million and $219 million, respectively. For 2025, the only jurisdiction with income taxes paid (net of refunds) in excess of the 5% reporting threshold was domestic federal income taxes of $284 million.

At December 31, 2025, for income tax reporting purposes, the Company had net operating loss carryforwards of $214 million for federal, $24 million net operating loss carryforwards for international jurisdictions and $4.8 billion net operating loss carryforwards for state, portions of which expire in the years 2026 and thereafter. The state carryforward amount is derived from the operating results of certain subsidiaries.

A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows:

 

(in millions)

 

2025

 

 

2024

 

 

2023

 

Unrecognized tax benefits balance at January 1

 

$

4

 

 

$

5

 

 

$

3

 

Gross increases for tax positions of prior years

 

 

14

 

 

 

3

 

 

 

3

 

Gross decreases for tax positions of prior years

 

 

 

 

 

 

 

 

 

Settlements

 

 

 

 

 

(4

)

 

 

(1

)

Unrecognized tax benefits balance at December 31

 

$

18

 

 

$

4

 

 

$

5

 

The total amount of unrecognized tax benefits that would affect the Company’s effective tax rate if recognized was $18 million as of December 31, 2025, $4 million as of December 31, 2024 and $5 million as of December 31, 2023. The Company does not expect its unrecognized tax benefits to change significantly over the next 12 months.

The Company recognizes interest and penalties related to uncertain tax positions in income tax expense. As of December 31, 2025, 2024 and 2023, accrued interest and penalties related to uncertain tax positions were minimal.

The Company is subject to taxation in the United States and various state jurisdictions. The Company is also subject to taxation in various international jurisdictions throughout Europe and Asia. In the United States, federal returns for fiscal years 2022 through 2025 remain open and subject to examination by the Internal Revenue Service. The Company files and remits state income taxes in various states where the Company has determined it is required to file state income taxes. The Company’s filings with those states remain open for audit for the fiscal years 2022 through 2025. The Company files and remits income taxes in various international jurisdictions where the Company has determined it is required to file income taxes. The Company's filings with those countries remain open for audit for the fiscal years 2021 through 2025. The Company also operates in Bermuda and the Cayman Islands. The Company is not subject to any income taxes in these countries.

During the third quarter of 2023, the Company was notified by the State of California Franchise Tax Board regarding an audit for the 2020-2021 tax years for Saferide Motor Club, Inc. No additional correspondence has been received, and we are not aware of any amounts to reserve for at this time.

During 2025, the Company was notified by the State of New York regarding an audit for the 2021-2023 tax years for Brown & Brown, Inc. We are currently gathering requested information and are not aware of any amounts to reserve for this time.

In general, it is our practice and intention to reinvest the earnings of our non-U.S. subsidiaries in those operations. The Company has determined it is not practical to determine the unrecognized deferred tax liabilities on the undistributed earnings from the Company’s international subsidiaries as such earnings are considered to be indefinitely reinvested.

Historical Timeline

Fiscal YearFiled
2025Feb 12, 2026Showing above
2024Feb 13, 2025
2023Feb 22, 2024
2022Feb 27, 2023
2021Feb 23, 2022
2020Feb 23, 2021
2019Feb 24, 2020
2018Feb 26, 2019
2017Feb 28, 2018
2016Feb 24, 2017
2015Feb 26, 2016

About Income Taxes Disclosures

The income tax disclosure reveals how much a company actually pays in taxes versus what the statutory rate would predict. Analysts focus on the effective tax rate (ETR) reconciliation, which breaks down every item driving the gap between the 21% federal rate and the company's reported ETR — including R&D credits, foreign rate differentials, and state taxes. Deferred tax assets (DTAs) and their valuation allowances signal management's confidence in future profitability: a rising allowance suggests the company doubts it can use accumulated tax benefits. Uncertain tax benefit (UTB) reserves quantify exposure to IRS challenges on aggressive positions.

Key signals to watch: sudden ETR drops without clear operational reasons, large increases in valuation allowances, growing UTB balances, and significant unremitted foreign earnings. Post-TCJA, pay attention to GILTI and BEAT provisions that affect multinational tax structures. Compare the cash taxes paid (from the cash flow statement) against the income tax provision to gauge earnings quality.