Fidelity National Financial, Inc.FNF
Fidelity National Financial, Inc. Income Taxes Disclosure
Income Taxes
Income tax expense (benefit) on continuing operations consists of the following:
| Year Ended December 31, | |||||
| 2025 | |||||
| (In millions) | |||||
| Current tax expense | |||||
| Federal | $ | 76 | |||
| State | 23 | ||||
| Foreign | 16 | ||||
| Total current tax expense | $ | 115 | |||
| Deferred tax expense | |||||
| Federal | 599 | ||||
| State | 39 | ||||
| Total deferred tax expense | $ | 638 | |||
| Total income tax expense on continuing operations | $ | 753 | |||
| Year Ended December 31, | |||||||||||
| 2024 | 2023 | ||||||||||
| (In millions) | |||||||||||
| Current | $ | 360 | $ | 241 | |||||||
| Deferred | 7 | (49) | |||||||||
| $ | 367 | $ | 192 | ||||||||
Total income tax expense was allocated as follows:
| Year Ended December 31, | |||||
| 2025 | |||||
| (In millions) | |||||
| Net earnings from continuing operations | $ | 753 | |||
| Other comprehensive earnings (loss): | |||||
| Unrealized gain on investments and other financial instruments | 160 | ||||
| Unrealized gain on foreign currency translation | 4 | ||||
| Changes in current discount rate - future policy benefits | (62) | ||||
| Changes in instrument - specific credit risk - market risk benefits | (6) | ||||
| Tax effects of F&G Distribution | (16) | ||||
| Other comprehensive earnings attributable to non-controlling interest | (18) | ||||
| Total income tax expense allocated to other comprehensive earnings | 62 | ||||
| Total income taxes | $ | 815 | |||
| Year Ended December 31, | |||||||||||
| 2024 | 2023 | ||||||||||
| (In millions) | |||||||||||
| Net earnings from continuing operations | $ | 367 | $ | 192 | |||||||
| Other comprehensive earnings (loss): | |||||||||||
| Unrealized (loss) gain on investments and other financial instruments | (35) | 275 | |||||||||
| Unrealized (loss) gain on foreign currency translation | (6) | 2 | |||||||||
| Changes in current discount rate - future policy benefits | 59 | (50) | |||||||||
| Changes in instrument - specific credit risk - market risk benefits | 1 | (9) | |||||||||
F&G 15% Distribution | (3) | (35) | |||||||||
| Total income tax expense) allocated to other comprehensive earnings | 16 | 183 | |||||||||
| Total income tax expense | $ | 383 | $ | 375 | |||||||
A reconciliation of the federal statutory rate to our effective tax rate is as follows:
| Year Ended December 31, 2025 | |||||||||||
| (In millions) | |||||||||||
| Federal statutory rate | 21.0 | % | $ | 293 | |||||||
| State income taxes, net of federal income tax effect (1) | 1.9 | 26 | |||||||||
| Tax credits | (0.6) | (8) | |||||||||
| Changes in valuation allowances | (2.0) | (28) | |||||||||
| Outside basis difference in F&G (2) | 33.7 | 471 | |||||||||
| Nontaxable or nondeductible items and other | (0.1) | (1) | |||||||||
| Effective tax rate | 53.9 | % | $ | 753 | |||||||
(1) State taxes in California and Illinois made up the majority (greater than 50 percent) of the tax effect in this category.
(2) State taxes of $23 million are included in this category, of which Illinois and Florida made up the majority (greater than 50 percent).
| Year Ended December 31, | |||||||||||
| 2024 | 2023 | ||||||||||
| Federal statutory rate | 21.0 | % | 21.0 | % | |||||||
| State income taxes, net of federal benefit | 1.8 | 2.4 | |||||||||
| Stock compensation | (0.5) | (0.2) | |||||||||
| Tax credits | (0.7) | (1.8) | |||||||||
| Valuation allowance for deferred tax assets | (1.0) | 5.0 | |||||||||
| Officers Compensation | 0.8 | 1.2 | |||||||||
| Non-deductible expenses and other, net | (0.3) | 0.1 | |||||||||
| Effective tax rate | 21.1 | % | 27.7 | % | |||||||
Total income taxes paid was allocated as follows:
| Year Ended December 31, | |||||
| 2025 | |||||
| (In millions) | |||||
| Federal | $ | 198 | |||
| State & Foreign | 52 | ||||
| Total | $ | 250 | |||
The significant components of deferred tax assets and liabilities consist of the following:
| December 31, | |||||||||||
| 2025 | 2024 | ||||||||||
| (In millions) | |||||||||||
| Deferred Tax Assets: | |||||||||||
| Employee benefit accruals | $ | 138 | $ | 129 | |||||||
| Net operating loss carryforwards | 119 | 115 | |||||||||
| Tax credits | 176 | 204 | |||||||||
| Investment securities | 504 | 775 | |||||||||
| Capital loss carryover | 2 | 19 | |||||||||
| Life insurance and claim related adjustments | 539 | 451 | |||||||||
| Funds held under reinsurance agreements | 1,178 | 822 | |||||||||
| Market Risk Benefits | 99 | 56 | |||||||||
| Bermuda corporate income tax net operating loss carryforward | — | 10 | |||||||||
| Section 263a Costs | 30 | — | |||||||||
| Other | 36 | 42 | |||||||||
| Total gross deferred tax asset | 2,821 | 2,623 | |||||||||
| Less: valuation allowance | 114 | 164 | |||||||||
| Total deferred tax asset | $ | 2,707 | $ | 2,459 | |||||||
| Deferred Tax Liabilities: | |||||||||||
| Title plant | $ | (54) | $ | (53) | |||||||
| Amortization of goodwill and intangible assets | (97) | (71) | |||||||||
| Other | (7) | (11) | |||||||||
| Depreciation | (21) | (24) | |||||||||
| Partnerships | (277) | (198) | |||||||||
| Value of business acquired | (251) | (283) | |||||||||
| Deferred acquisition costs | (677) | (543) | |||||||||
| Outside basis difference in F&G | (404) | — | |||||||||
| Funds held under reinsurance agreements | (1,261) | (945) | |||||||||
| Title Insurance reserve discounting | (17) | (16) | |||||||||
| Total deferred tax liability | $ | (3,066) | $ | (2,144) | |||||||
| Net deferred tax (liability) asset | $ | (359) | $ | 315 | |||||||
Our net deferred tax (liability) asset was $(359) million and $315 million as of December 31, 2025 and 2024, respectively. The significant changes in the deferred taxes are as follows: the deferred tax asset for investment securities decreased by $271 million primarily due to unrealized gains recorded for investment securities, of which $29 million was related to unrealized gains in our Title segment and $242 million was related to unrealized gains in our F&G segment's life insurance business. The deferred tax liability related to deferred acquisition costs increased by $134 million, which is consistent with the growth in sales in our F&G segment. The reinsurance receivable deferred tax asset increased by $356 million and the reinsurance receivable deferred tax liability increased by $316 million, both due to the increase in modified coinsurance reinsurance in the F&G segment. The deferred tax asset relating to life insurance receivables increased by $88 million primarily due to GAAP reserves increasing more than tax reserves by F&G. The deferred tax liability relating to partnerships increased by $79 million, of which $30 million relates to partnerships in our Title segment and $49 million relates to partnerships in our F&G segment. In connection with the 2025 F&G distribution, we recorded a deferred tax liability of $404 million for our outside basis difference in F&G. This deferred tax liability represents the difference between the book basis and tax basis of the retained F&G shares as of December 31, 2025, as we can no longer recover our investment tax free. $471 million was recorded through continuing operations, with the remaining movement in the deferred tax liability recorded through other comprehensive income and equity, following the accounting guidance regarding intraperiod allocation under ASC 740 and ASC 810. As a
result of the 2025 F&G distribution, certain F&G subsidiaries who have historically filed a consolidated tax return with FNF will no longer be eligible to file a consolidated tax return after the 2025 tax year.
As of December 31, 2025, we have net operating losses ("NOLs") on a pretax basis of $548 million, of which $42 million relates to our Title segment and $506 million relates to our F&G segment's life insurance business, which are available to carryforward and offset future federal taxable income. The Title segment NOLs are U.S. federal NOLs arising from acquisitions made since 2012, including Buyers Protection Group, Inc., Digital Insurance Holdings, Inc. and THL Corporations (ServiceLink). Most of the NOLs are subject to an annual Internal Revenue Code Section 382 limitation. These losses will begin to expire in year 2034 and we fully anticipate utilizing the Title segment losses prior to expiration with the exception of $25 million of gross net operating losses that are offset by a $25 million valuation allowance in the Title segment. The F&G NOLs are indefinite life U.S. federal NOLs arising from the life insurance business.
As of December 31, 2025 and 2024, we had $176 million and $204 million of tax credits, respectively, some of which have expiration dates and will begin to expire between 2029 and 2044. The credits primarily consist of general business credits and corporate alternative minimum tax credits, including $124 million associated with our F&G segment's life insurance business. Our corporate alternative minimum tax credit has an indefinite life. We anticipate the remainder of the credits will be utilized prior to expiration with the exception of $31 million relating primarily to general business credits in our Title segment which have a corresponding $31 million valuation allowance recorded.
As of December 31, 2025, a valuation allowance of $71 million on the net deferred tax asset for capital losses was recorded, of which $34 million related to the Title segment and $37 million related to the F&G segment. The net change in the capital loss valuation allowance was a $48 million decrease for the year ended December 31, 2025. This decrease to the valuation allowance was primarily due to fluctuations in the bond and equity markets, and to capital gains and losses generated in 2025.
As of December 31, 2025 and 2024, there were no unrecognized tax benefits.
F&G's life insurance subsidiaries, as well as certain F&G non-life subsidiaries file separate tax returns from the FNF consolidated group. Prepaid expenses and other assets in the accompanying Consolidated Balance Sheets as of December 31, 2025, includes: $82 million of deferred tax assets as well as $84 million of tax receivables related to F&G subsidiaries who file separate tax returns. As of December 31, 2024, prepaid expenses and other assets included $20 million of deferred tax assets related to the FNF consolidated group as well as $6 million of tax receivables and $295 million of deferred tax assets related to F&G subsidiaries who file separate tax returns.
We continue to be a participant in the Internal Revenue Service (“IRS”) Compliance Assurance Process that is a real-time audit. The 2025 U.S. federal income tax return remains open to examination by the IRS. We file income tax returns in various foreign and US state jurisdictions. Our state income tax returns for the 2021 through 2025 tax years remain subject to examination by state jurisdictions. The F&G life insurance group files a separate consolidated return with the IRS. The F&G federal income tax returns for 2020 through the current period remain open to examination by the IRS.
The Organization for Economic Cooperation and Development has developed guidance known as the Global Anti-Base Erosion Pillar Two minimum tax rules, or Pillar Two, which generally provide for a minimum effective tax rate of 15% and are intended to apply to tax years beginning in 2024. As of December 31, 2025, based on the countries in which we do business that have enacted legislation, the Company does not expect these rules to have a material impact on our income tax provision.
On July 4, 2025, the One Big Beautiful Bill Act ("OBBBA") was signed into law. The application of the OBBBA tax provisions did not result in material changes to the Company's total income tax expense or effective tax rate for the year ended December 31, 2025.
The Company considers its non-U.S. earnings to be indefinitely reinvested outside of the U.S. to the extent these earnings are not subject to the U.S. income tax under an anti-deferral tax regime. Given our intent to reinvest these earnings for an indefinite period of time, the Company has not accrued a deferred tax liability on these earnings. A determination of an unrecognized deferred tax liability related to these earnings is not practicable.
Historical Timeline
| Fiscal Year | Filed | |
|---|---|---|
| 2025 | Feb 26, 2026 | Showing above |
| 2024 | Feb 28, 2025 | |
| 2023 | Feb 29, 2024 | |
| 2022 | Feb 27, 2023 | |
| 2021 | Feb 25, 2022 | |
| 2020 | Mar 1, 2021 | |
| 2019 | Feb 14, 2020 | |
| 2018 | Feb 19, 2019 | |
| 2017 | Feb 23, 2018 | |
| 2016 | Feb 27, 2017 | |
| 2015 | Feb 23, 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.