Income Taxes
The consolidated income tax expense consists of the following ($ in millions):
Year Ended December 31,
 202520242023
Income (loss) from continuing operations before income tax expense (benefit)
U.S. Federal$(6,727)$3,529 $3,686 
Foreign (1)
(1)728 (88)
Total$(6,728)$4,257 $3,598 
Income tax expense (benefit) from continuing operations
Current tax expense (benefit)
Federal$77 $798 $833 
State and local(69)142 132 
Foreign— — 
Total current tax expense$$940 $966 
Deferred tax expense (benefit)
Federal$(29)$$(71)
State and local(30)33 
Foreign— (29)
Total deferred tax expense (benefit)$(59)$23 $(67)
Total income tax expense (benefit)
Federal$48 $806 $762 
State and local(99)149 165 
Foreign— (28)
Total income tax expense (benefit)$(51)$963 $899 
(1)
Foreign income from continuing operations includes the Company's Cayman Islands reinsurance entity. The Company has elected for its Cayman Islands entity to be taxed as a U.S. corporation and pays U.S. tax at the 21% tax rate. The U.S. tax resulting from this entity is included in Federal income tax expense. This entity ceased operations in 2025.
The reconciliation of the tax provision at the U.S. federal statutory rate to income tax expense (benefit) is as follows ($ in millions):
Year Ended December 31,
 202520242023
Total%Total%Total%
Earnings (loss) from continuing operations, before income tax expense$(6,728)$4,257 $3,598 
Tax provision at the U.S. federal statutory rate(1,413)21.0 %894 21.0 %756 21.0 %
Federal
Effect of cross-border tax laws
Global Intangible Low-Taxed Income (GILTI)(2)— %44 1.0 %0.1 %
Cayman Islands
Statutory income tax rate differential (1)
— — %142 3.3 %62 1.7 %
Other— %— %(21)(0.6)%
Tax credits— — %(14)(0.3)%(5)(0.1)%
Changes in valuation allowances(1)— %(12)(0.3)%(2)(0.1)%
Nontaxable or nondeductible items
Nondeductible compensation31 (0.5)%37 0.9 %29 0.8 %
Nondeductible goodwill1,409 (20.9)%— — %— — %
Nontaxable or nondeductible divestiture (gains) losses— %(97)(2.3)%(9)(0.3)%
Other nontaxable or nondeductible items19 (0.3)%(1)— %(6)(0.2)%
Other
Excess tax detriment (benefit) on stock awards(0.1)%(3)(0.1)%(59)(1.6)%
Other(24)0.4 %0.2 %26 0.7 %
Foreign tax effects
United Kingdom
Nondeductible goodwill— — %(34)(0.8)%83 2.3 %
Other— — %12 0.3 %(26)(0.7)%
Cayman Islands
Statutory income tax rate differential (1)
— — %(142)(3.3)%(62)(1.7)%
Other jurisdictions— — %0.2 %(16)(0.4)%
Changes in unrecognized tax benefits(92)1.4 %24 0.6 %27 0.8 %
State income taxes, net of federal income tax benefit (2)
13 (0.2)%95 2.2 %118 3.3 %
Income tax (benefit) expense$(51)0.8 %$963 22.6 %$899 25.0 %
(1)
The Company has elected for its Cayman Islands reinsurance entity to be taxed as a U.S. corporation and pays U.S. tax at the 21% tax rate. The taxability of this entity does not represent a reconciling item between the U.S. federal rate and the Company's effective tax rate. This entity ceased operations in 2025.
(2)
During the year ended December 31, 2025, state taxes in Pennsylvania comprised greater than 50% of the tax effect in this category. During the year ended December 31, 2024, state taxes in California, Florida and Illinois comprised greater than 50% of the tax effect in this category. During the year ended December 31, 2023, state taxes in California and Florida comprised greater than 50% of the tax effect in this category.
Income taxes paid are as follows ($ in millions):
Year Ended December 31,
202520242023
U.S. Federal (1)
$364 $930 $698 
California27 **
Florida23 **
Pennsylvania**53 
Other (2)
34 71 138 
Total U.S. State and Local 84 71 191 
Foreign 1(2)
Total income taxes paid, net$448 $1,002 $887 
(1)
Includes amounts paid to purchase transferable tax credits of $78 million, $100 million and $49 million during the years ended December 31, 2025, 2024 and 2023, respectively.
(2)
Includes amounts paid to purchase transferable tax credits of $23 million, $15 million and $10 million during the years ended December 31, 2025, 2024 and 2023, respectively.
*
The amount of income taxes paid to these jurisdictions during the year does not meet the 5% disaggregation threshold.

The tax effects of temporary differences which give rise to deferred tax assets and liabilities are presented below ($ in millions):
 December 31, 2025December 31, 2024
Deferred tax assets:
Medical claims liability$178 $178 
Nondeductible liabilities69 81 
Net operating loss and other carryforwards106 70 
Compensation accruals105 93 
Premium and trade receivables88 72 
Operating lease liability196 231 
Unrealized gain/loss13 153 
Software development costs178 246 
Other48 92 
Deferred tax assets981 1,216 
Valuation allowance(67)(77)
Net deferred tax assets$914 $1,139 
Deferred tax liabilities:
Goodwill and intangible assets$1,376 $1,518 
Fixed assets198 135 
Investments in subsidiaries and joint ventures (outside basis)68 — 
Right-of-use asset78 88 
Other27 82 
Deferred tax liabilities1,747 1,823 
Net deferred tax liabilities$(833)$(684)

Valuation allowances are provided when it is considered more likely than not that deferred tax assets will not be realized. The valuation allowances primarily relate to future tax benefits on certain state net operating loss and capital loss carryforwards and federal and state tax credit carryforwards.
State net operating loss and tax credit carryforwards of $45 million expire beginning in 2026 through 2044, while the remaining $16 million have indefinite carryforward periods.

The Company maintains a reserve for uncertain tax positions that may be challenged by a tax authority. A rollforward of the beginning and ending amount of uncertain tax positions, exclusive of related interest and penalties, is as follows ($ in millions):
Year Ended December 31,
 20252024
Gross unrecognized tax benefits, January 1$340 $439 
Gross increases:
Current year tax positions12 16 
Prior year tax positions31 
Gross decreases:
Settlements (1)
(8)(133)
Prior year tax positions(8)(6)
Statute of limitation lapses(110)(7)
Gross unrecognized tax benefits, December 31$230 $340 
(1)
Settlements for the year ended December 31, 2024 primarily reflected the resolution of an item that had no net impact on the Consolidated Statement of Operations.

As of December 31, 2025, $120 million of unrecognized tax benefits would impact the Company's effective tax rate in future periods, if recognized.

The table above excludes interest and penalties, net of related tax benefits, which are treated as income tax expense (benefit) under the Company's accounting policy. The Company recognized a net reduction of interest expense and penalties related to uncertain positions of $37 million for the year ended December 31, 2025. For the year ended December 31, 2024, the Company recognized net interest expense and penalties related to uncertain positions of $13 million. The Company had $61 million and $98 million of accrued interest and penalties for uncertain tax positions as of December 31, 2025 and 2024, respectively.

The Company files federal tax returns as well as returns for numerous state tax jurisdictions and is engaged in multiple audit proceedings for its state filings. Generally, no further state audit activity is expected for years prior to 2016. Additionally, the Company's tax returns are under federal examination for tax years 2021 through 2022.

Historical Timeline

Fiscal YearFiled
2025Feb 17, 2026Showing above
2017Feb 20, 2018

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.