Note 21 – Income Taxes
Accounting Policy. Deferred income taxes are reflected in the Consolidated Balance Sheets for differences between the financial and income tax reporting bases of the Company's underlying assets and liabilities and are established based upon enacted tax rates and laws. Deferred income tax assets are recognized when available evidence indicates that realization is more likely than not, and a valuation allowance is established to the extent this standard is not met. The deferred income tax provision generally represents the net change in deferred income tax assets and liabilities during the reporting period excluding adjustments to Accumulated other comprehensive income (loss) or amounts recorded in connection with a business combination. The current income tax provision generally represents estimated amounts due on income tax returns for the year reported to various jurisdictions plus the effect of any uncertain tax positions. The Company uses the deferral method of accounting on investments that generate tax credits. Under this method, the investment tax credits are recognized as a reduction to the related asset, which are generally reported in Other assets in the Consolidated Balance Sheets. The Company recognizes a liability for uncertain tax positions if management believes the probability that the positions will be sustained is 50% or less. For uncertain positions that management believes are more likely than not to be sustained, the Company recognizes a liability based upon management's estimate of the most likely settlement outcome with the taxing authority. The liabilities for uncertain tax positions are classified as current when the position is expected to be settled within 12 months or the statute of limitation expires within 12 months.
Income taxes attributable to the Company's foreign operations are provided using the foreign jurisdictions' applicable tax rate.
The Company prospectively adopted ASU 2023-09, Improvements to Income Tax Disclosures. As a result, disclosures for 2025 reflect the requirements of ASU 2023-09, including the reconciliation of the statutory federal income tax rate and disaggregated tax payment information. Prior years (2024 and 2023) are presented under the previous disclosure requirements.
Income Tax ExpenseThe components of income taxes were as follows: | | | | | | | | | | | | | | | | | | | | |
| | For the Years Ended December 31, |
| (In millions) | | 2025 | | 2024 | | 2023 |
| Current taxes | | | | | | |
| U.S. income taxes | | $ | 807 | | | $ | 1,167 | | | $ | 1,459 | |
| Foreign income taxes | | 191 | | | 248 | | | 161 | |
| State income taxes | | 169 | | | 171 | | | 180 | |
| Total current taxes | | 1,167 | | | 1,586 | | | 1,800 | |
| Deferred taxes (tax benefits) | | | | | | |
U.S. income tax benefits | | (69) | | | (142) | | | (533) | |
Foreign income taxes (tax benefits) | | 447 | | | 64 | | | (1,046) | |
State income tax benefits | | (52) | | | (17) | | | (80) | |
Total deferred taxes (tax benefits) | | 326 | | | (95) | | | (1,659) | |
| Total income taxes | | $ | 1,493 | | | $ | 1,491 | | | $ | 141 | |
Total income taxes were different from the amount computed using the statutory federal income tax rate in 2025 for the following reasons:
| | | | | | | | | | | | |
| For the Year Ended December 31, |
| 2025 | | |
| (in millions) | $ | % | | | | |
| Tax expense at statutory rate | $ | 1,634 | | 21.0 | % | | | | |
State income tax effect, net of federal income tax effect (1) | 93 | | 1.2 | | | | | |
| Nontaxable or nondeductible items | 13 | | 0.2 | | | | | |
| Effects of cross-border tax laws: | | | | | | |
| Global intangible low-taxed income ("GILTI") | 127 | | 1.6 | | | | | |
| Other cross-border tax laws | 11 | | 0.1 | | | | | |
| Tax credits | (83) | | (1.1) | | | | | |
| Change in valuation allowance | (74) | | (1.0) | | | | | |
| Change in unrecognized tax benefits | 37 | | 0.5 | | | | | |
| Other | | | | | | |
| Impact of sale of business | (173) | | (2.2) | | | | | |
| Tax equity investments | (102) | | (1.3) | | | | | |
| Other reconciling items | 3 | | 0.2 | | | | | |
| Foreign tax effects: | | | | | | |
| Switzerland | | | | | | |
| Effect of rates different than U.S. statutory | (360) | | (4.6) | | | | | |
| Cantonal income taxes | 206 | | 2.6 | | | | | |
| Change in valuation allowance | 384 | | 4.9 | | | | | |
| | | | | | |
| Other countries | (223) | | (2.9) | | | | | |
| Total income taxes | $ | 1,493 | | 19.2 | % | | | | |
(1) The jurisdictions that make up the majority (greater than 50 percent) of the state and local tax impact are Florida and California.
Total income taxes were different from the amount computed using the statutory federal income tax rate in 2024 and 2023 for the following reasons:
| | | | | | | | | | | | | | | | | | | | | | | | | | | |
| | For the Years Ended December 31, |
| | 2024 | | 2023 | |
| (In millions) | $ | | % | | $ | | % | |
| Tax expense at statutory rate | $ | 1,107 | | | 21.0 | | % | $ | 1,158 | | | 21.0 | | % |
| Change in valuation allowance | 767 | | | 14.6 | | | 1,290 | | | 23.4 | | |
| State income tax effect, net of federal income tax effect | 62 | | | 1.2 | | | (39) | | | (0.7) | | |
| Investment tax credits | (111) | | | (2.1) | | | (48) | | | (0.8) | | |
| Impact of businesses held for sale | (129) | | | (2.4) | | | (213) | | | (3.9) | | |
| Effect of foreign earnings | (252) | | | (4.9) | | | (173) | | | (3.1) | | |
| Other foreign tax attributes | — | | | — | | | (153) | | | (2.8) | | |
| Swiss tax attributes | — | | | — | | | (1,674) | | | (30.4) | | |
| | | | | | | | | |
| | | | | | | | | |
| Other | 47 | | | 0.9 | | | (7) | | | (0.1) | | |
| Total income taxes | $ | 1,491 | | | 28.3 | | % | $ | 141 | | | 2.6 | | % |
Tax Equity Investments. Company investments in renewable energy projects provided $968 million, $1,057 million and $453 million of investment tax credits for the years ended December 31, 2025, 2024 and 2023, respectively. The Company accounted for the tax credits using the deferral method and accordingly reduced the associated carrying value of the related assets by these amounts.
Pre-tax Income Disaggregation. Consolidated pre-tax income from the Company's foreign operations was approximately 53% of the Company's pre-tax income in 2025, 62% in 2024 and 48% in 2023. The change relative to 2024 is primarily attributable to lower 2024 domestic earnings driven by the impairment of equity securities in 2024 (see Note 11 to the Consolidated Financial Statements).
Deferred Income TaxesDeferred income tax assets and liabilities were as follows: | | | | | | | | | | | | | | | |
| (In millions) | | December 31, 2025 | | December 31, 2024 |
| Deferred tax assets | | | | |
| Foreign tax attributes | | $ | 1,615 | | | $ | 1,752 | |
| Deferred loss - sale of business | | — | | | 773 | |
| Investments | | 587 | | | 561 | |
| Other insurance and contractholder liabilities | | 241 | | | 300 | |
| Loss carryforwards | | 492 | | | 270 | |
| Other accrued liabilities | | 321 | | | 207 | |
| Employee and retiree benefit plans | | 190 | | | 177 | |
| Unrealized depreciation on investments and foreign currency translation | | 10 | | | 93 | |
| Policy acquisition expenses | | 53 | | | — | |
| Other | | 339 | | | 256 | |
| Deferred tax assets before valuation allowance | | 3,848 | | | 4,389 | |
| Valuation allowance for deferred tax assets | | (2,374) | | | (2,332) | |
| Deferred tax assets, net of valuation allowance | | 1,474 | | | 2,057 | |
| Deferred tax liabilities | | | | |
| Acquisition-related basis differences | | 7,558 | | | 7,822 | |
| Depreciation and amortization | | 602 | | | 243 | |
| Policy acquisition expenses | | — | | | 74 | |
| | | | | |
| | | | | |
| | | | | |
| | | | | |
| Total deferred tax liabilities | | 8,160 | | | 8,139 | |
| Net deferred income tax liabilities (1) | | $ | (6,686) | | | $ | (6,082) | |
| | | | | |
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(1)Deferred tax liabilities, net in the Consolidated Balance Sheets excludes $459 million and $954 million reported in Other assets as of December 31, 2025 and December 31, 2024, respectively, and $61 million reported in liabilities of businesses held for sale as of December 31, 2024.
Management believes that it is more likely than not that future results will be sufficient to realize the Company's gross deferred tax assets ("DTAs") that remain after valuation allowance. Valuation allowances have been established against certain federal, state and foreign tax attributes. There are multiple expiration dates associated with these tax attributes.
Foreign Jurisdiction Tax Attributes. As of December 31, 2025 and 2024, the Company had DTAs of approximately $1.6 billion and $1.8 billion, respectively, and had a related $1.2 billion and $0.8 billion valuation allowance, respectively, against these deferred tax assets based on projections of future earnings and requirements to utilize the assets within certain time periods. In 2025, the Company recorded an increase to the valuation allowance as a result of management's reassessment of the composition of future foreign and domestic earnings. It is possible that the Company may revalue these net deferred tax assets in future periods due to modifications in certain assumptions, such as forecasted future earnings.
Capital DTAs: Impairments, Unrealized Investment Losses and Sale of Medicare Advantage and Related Businesses. As of December 31, 2025 and 2024, the Company had approximately $819 million and $880 million, respectively, in DTAs associated with the impairment of equity securities and other unrealized investment losses (see Note 11 to the Consolidated Financial Statements), as well as $237 million and $773 million, respectively, of DTAs in connection with the HCSC transaction, reflecting total capital DTAs of approximately $1,056 million and $1,653 million, respectively. A valuation allowance of $1,025 million and $1,351 million, respectively, has been established against these DTAs as of December 31, 2025 and 2024 due to the uncertainty relative to the recovery of the deferred tax benefits as the Company does not anticipate having sufficient sources of capital income to support these capital losses. We have determined that a valuation allowance against the remaining capital DTAs is not currently required based on the Company's loss carryback capacity and ability and intent to hold certain investment securities until recovery. We continue to monitor and evaluate the need for any additional valuation allowance.
During 2025, the reallocation of the HCSC transaction purchase price by legal entity resulted in an equal write-off of the DTAs and valuation allowance associated with the tax-deductible capital loss on the sale, resulting in zero net impact to the Company's total tax provision. Additionally, a reallocation of available sources of capital income generated a substantial portion of the after-tax gain on sale presented in Note 5 to the Consolidated Financial Statements. There was no material change to the realizability assessment of the Company's consolidated DTAs and no material net impact to the Company's consolidated tax expense as a result of this reallocation.
Uncertain Tax PositionsReconciliations of unrecognized tax benefits were as follows: | | | | | | | | | | | | | | | | | | | | |
| | For the Years Ended December 31, |
| (In millions) | | 2025 | | 2024 | | 2023 |
| Balance at January 1, | | $ | 1,477 | | | $ | 1,399 | | | $ | 1,343 | |
Decrease due to prior year positions | | (50) | | | (7) | | | (26) | |
| | | | | | |
Increase due to current year positions | | 187 | | | 165 | | | 107 | |
Reduction related to settlements with taxing authorities | | (62) | | | (22) | | | (13) | |
Reduction related to lapse of applicable statute of limitations | | (14) | | | (58) | | | (12) | |
| Balance at December 31, | | $ | 1,538 | | | $ | 1,477 | | | $ | 1,399 | |
Substantially all unrecognized tax benefits would increase Shareholders' net income if recognized.
The Company classifies net interest expense on uncertain tax positions as a component of income tax expense and in Other non-current liabilities in the Consolidated Balance Sheets. In addition to the amounts in the table above, the liability for net interest expense on uncertain tax positions was approximately $223 million, $228 million and $220 million as of December 31, 2025, 2024 and 2023, respectively.
Other Tax MattersThe statutes of limitations for the Company's consolidated federal income tax returns through 2016 have closed. The statute of limitations for the Company's 2020 and 2021 tax returns have also closed. However, The Cigna Group filed amended returns for both the 2015 and 2016 tax years, which are under review by the Internal Revenue Service ("IRS"). Additionally, the IRS is examining the Company's returns for 2017, 2018, 2019, 2022 and 2023. The IRS has examined Express Scripts' tax returns for 2010 through 2017, for which there remain significant disputed matters. In addition, the Company has pending refund claims for various years. The Company has established adequate reserves for these matters.
The Company conducts business in a number of state and foreign jurisdictions and may be engaged in multiple audit proceedings at any given time. Generally, no further state or foreign audit activity is expected for tax years prior to 2013 for Express Scripts entities and 2014 for all other entities of The Cigna Group.
Pillar Two. The Organization for Economic Co-operation and Development ("OECD") Pillar Two Framework defines a minimum effective tax rate of 15%. The Company is within the scope of the OECD Pillar Two model rules, which did not have a significant impact on our 2025 results. We will continue to monitor the potential impact on future periods but do not currently expect Pillar Two to significantly impact future periods.
Income Taxes PaidFor the year ended December 31, 2025, the Company made tax payments, net of refunds, in the amount of $399 million to the following jurisdictions: U.S. federal refund ($4 million), U.S. state payment ($140 million), and foreign payments ($263 million), primarily Switzerland. The Company’s federal tax payments reflect the benefit of $968 million of renewable energy tax credits, which have been applied against the Company’s federal tax liability under existing tax rules.
For the years ended December 31, 2024 and 2023, the company made tax payments, net of refunds in the amount of $898 million and $1,471 million, respectively. For the years ended December 31, 2024 and 2023, the Company’s federal tax payments reflect the benefit of $1,057 million and $453 million, respectively, of renewable energy tax credits, which were applied against the Company’s federal tax liability under existing tax rules.