INCOME TAX
Pre-tax income for the years ended December 31, 2025, 2024 and 2023 consists of the following (dollars in millions): 
202520242023
Pre-tax income – U.S.
$1,224 $572 $898 
Pre-tax income – foreign
316 408 262 
Total pre-tax income$1,540 $980 $1,160 
The provision for income tax expense for the years ended December 31, 2025, 2024 and 2023 consists of the following (dollars in millions):
 202520242023
Current income tax expense (benefit):
U.S. federal$196 $148 $(20)
U.S. state
Foreign(187)167 58 
Total current11 317 40 
Deferred income tax expense (benefit):
U.S. federal(13)(129)236 
U.S. state— — — 
Foreign353 68 (25)
Total deferred340 (61)211 
Total provision for income taxes$351 $256 $251 
The effective tax rate for 2025 was higher than the U.S. statutory rate of 21% primarily due to income earned in Canada and tax expense related to legal entity restructuring, which were partially offset by U.S. taxation of foreign earnings net of foreign tax credits and release of valuation allowances.
The effective tax rate for 2024 was higher than the U.S. statutory rate of 21% primarily due to income earned in non-U.S. jurisdictions and the tax expense related to legal entity restructuring, which were partially offset by benefits due to the release of valuation allowances in non-U.S. jurisdictions and benefits related to return to provision adjustments.
The Organization for Economic Cooperation and Development (“OECD”) developed Model Global Anti-Base Erosion (“GloBE”) rules under Pillar II establishing a Global Minimum Tax to ensure that multinational enterprises with consolidated revenue of more than EUR 750 million pay at least an effective tax rate of 15% on income arising in each jurisdiction in which they operate. As of December 31, 2025, many of the jurisdictions in which the Company operates had enacted Pillar II legislation into domestic law with an effective date of January 1, 2025. The Company recorded a tax expense of $10 million and $5 million related to Pillar II in 2025 and 2024, respectively. Subsequent to December 31, 2025, the OECD member countries agreed to a side-by-side system which is expected to result in further enactment of the changes. Expected future guidance could result in further changes to taxation.
The One Big Beautiful Bill Act (“OBBBA”) was enacted on July 4, 2025. The OBBBA makes permanent key elements of the Tax Cuts and Jobs Act of 2017, including 100 percent bonus depreciation, domestic research expenditure expensing, and makes modifications to the international tax framework. The tax impact of the OBBBA on the Company was immaterial for 2025.
The Inflation Reduction Act of 2022 (the “Act”) was enacted in 2022. For tax years ending after December 31, 2022, the Act imposed a 15% minimum tax on adjusted financial statement income for “applicable corporations” with average adjusted financial statement income over $1 billion for the previous 3-year period ending in 2022 or after. The Company is not an applicable corporation for 2025. The Act also imposes a 1% excise tax on stock buybacks of a publicly traded corporation. The tax impact of the Act was immaterial to the Company for 2025.
Bermuda enacted the Corporate Income Tax Act of 2023 on December 27, 2023. Effective as of January 1, 2025, Bermuda imposed a 15% corporate income tax rate applicable to resident Bermuda companies and permanent establishments with consolidated annual revenue of EUR 750 million or more. The impact was immaterial to the Company for 2025.
The Company adopted ASU 2023-09 “Income Taxes (Topic 740): Improvements to Income Tax Disclosures” on a prospective basis beginning with the year ended December 31, 2025. The following table presents the required rate reconciliation disclosure pursuant to ASU 2023-09 for the year ended December 31, 2025. The Company’s effective tax rate differed from the U.S. federal income tax statutory rate of 21% as a result of the following for the year ended December 31, 2025 (dollars in millions):
2025% of Total
U.S. Federal Statutory Tax Rate$322 21.0 %
State and Local Income Taxes, Net of Federal Income Tax Effect (1)
0.1 
Foreign Tax Effects
India
Statutory tax rate difference between India and United States(2)(0.1)
Changes in valuation allowance(30)(2.0)
Tax effects of reorganization27 1.8 
Canada28 1.8 
Other foreign jurisdictions(13)(0.8)
Effect of Cross-Border Tax Laws
Subpart F income, net of credits(33)(2.2)
Other0.4 
Changes in Valuation Allowance0.1 
Nontaxable or Nondeductible Items(8)(0.5)
Changes in Unrecognized Tax Benefits0.2 
Other Reconciling Items
Legal entity restructuring49 3.2 
Other(1)(0.1)
Effective Tax Rate (2)
$351 22.9 %
(1)    State taxes in Illinois made up the majority (greater than 50 percent) of the tax effect in this category.
(2)    The Company rounds amounts in the financial statements to millions and calculates the effective tax rate from the underlying whole dollar amounts. Thus, certain amounts may not recalculate based on the numbers due to rounding.
The following table presents the Company’s effective tax rate reconciliation prior to the adoption of ASU 2023-09. The Company’s effective tax rate differed from the U.S. federal income tax statutory rate of 21% as a result of the following for the years ended December 31, 2024 and 2023 (dollars in millions):
20242023
Tax provision at U.S. statutory rate$206 $244 
Increase (decrease) in income taxes resulting from:
Tax rate differences on income in other jurisdictions44 14 
Differences in tax basis in foreign jurisdictions(18)
Deferred tax valuation allowance(5)15 
Amounts related to uncertain tax positions(2)
Compensation
Corporate rate changes(4)— 
GILTI, net of credits14 — 
Subpart F for non-full inclusion companies26 28 
Foreign tax credits(5)(42)
Return to provision and amended adjustments(17)(9)
Pillar II— 
Effects of tax law changes and legal entity restructuring— 
Other, net(2)(3)
Total provision for income taxes$256 $251 
Effective tax rate (1)
26.3 %21.8 %
(1)    The Company rounds amounts in the financial statements to millions and calculates the effective tax rate from the underlying whole dollar amounts. Thus, certain amounts may not recalculate based on the numbers due to rounding.
Total income taxes for the years ended December 31, 2025, 2024 and 2023 were as follows (dollars in millions):
202520242023
Provision for income taxes$351 $256 $251 
Income tax from OCI and additional paid-in-capital:
Net unrealized investment gains (losses) recognized in OCI(100)(176)449 
Liability for future policyholder benefits564 586 (161)
Market risk benefits— — (3)
Foreign currency translation(17)32 22 
Unrealized pension and postretirement(2)
   Total income taxes provided$802 $700 $556 
The tax effects of temporary differences that give rise to significant portions of the deferred income tax assets and liabilities as of December 31, 2025 and 2024 are presented in the following table (dollars in millions):
 20252024
Deferred income tax assets:
Nondeductible accruals$85 $102 
Net operating loss carryforward829 846 
Capital loss carryforwards92 
Tax credit carryforward133 220 
Invested assets1,621 1,407 
Anticipated future foreign tax credit511 442 
Subtotal3,182 3,109 
Valuation allowance(726)(678)
Total deferred income tax assets2,456 2,431 
Deferred income tax liabilities:
Deferred acquisition costs644 931 
Policy reserves and other reinsurance liabilities4,569 3,428 
Foreign currency translation162 190 
Anticipated future foreign tax credit reduction— — 
Other
Total deferred income tax liabilities5,376 4,552 
Net deferred income tax liabilities$2,920 $2,121 
Balance sheet presentation of net deferred income tax liabilities:
Deferred tax assets, included in “Other assets”50 78 
Deferred tax liabilities, included in “Income taxes”2,970 $2,199 
Net deferred income tax liabilities$2,920 $2,121 
Balance sheet presentation of net income tax liabilities:
Deferred tax liabilities$2,970 $2,199 
Current taxes payable28 — 
Income taxes$2,998 $2,199 
As of December 31, 2025, the valuation allowance against deferred tax assets was $726 million. The valuation allowance primarily relates to the deferred taxes associated with foreign tax credit carryforwards in the U.S. and Ireland and losses in foreign subsidiaries that do not have a history of income. The Company reduced the deferred tax assets to the amount more likely than not to be realized.
As of December 31, 2024, the valuation allowance against deferred tax assets was $678 million. The valuation allowance was primarily related to the deferred taxes associated with mark-to-market losses in AOCI and losses in foreign subsidiaries that do not have a history of income. The Company reduced the deferred tax assets to the amount more likely than not to be realized.
The earnings of substantially all of the Company’s foreign subsidiaries have been permanently reinvested in foreign operations. The determination of the unrecognized deferred tax liability for temporary differences related to investments in the Company’s foreign subsidiaries is not practicable. U.S. tax law generally eliminates U.S. federal income taxes on dividends from foreign subsidiaries; the Company does not expect to incur material income taxes if these funds were repatriated.
During 2025, the Company made income tax payments to the following jurisdictions, net of refunds (dollars in millions).
2025
U.S. federal$49 
U.S. state and local1
Total U.S.$50 
Foreign
Canada127 
Hong Kong31 
Japan20 
All Other24 
Total foreign$202 
 Total income taxes paid, net of refunds$252 
During 2024 and 2023, the Company received federal and foreign income tax refunds of approximately $12 million and $13 million, respectively. The Company made cash income tax payments of approximately $90 million and $311 million in 2024 and 2023, respectively.
The following table presents consolidated net operating loss carryforwards (“NOL”) as of December 31, 2025 (dollars in millions):
2025
NOL with no expiration and with no valuation allowance$2,940 
NOL with a full valuation allowance232 
NOL with no expiration and a partial valuation allowance500 
NOL with expiration date of 2034 and no valuation allowance— 
Total net operating loss carryforwards$3,672 
These net operating losses, other than the net operating losses for which there is a valuation allowance, are expected to be utilized in the normal course of business during the period allowed for carryforwards and in any event are not expected to be lost due to the application of tax planning strategies that management would utilize.
As of December 31, 2025, the Company had foreign tax credit carryforwards of $133 million related to the U.S. and Ireland. The earliest year of expiration on the U.S. foreign tax credits is 2033. The U.S. credits have a partial valuation allowance of $54 million for the amount that is not more likely than not be utilized in the normal course of business. The Ireland foreign tax credit of $31 million has a full valuation allowance.
The Company files income tax returns in the U.S. federal jurisdiction and various state and foreign jurisdictions. The Company is subject to continuous examination by the Internal Revenue Service and is subject to audit by taxing authorities in other foreign jurisdictions in which the Company has business operations. The Company is no longer subject to audits in the U.S. federal jurisdiction for years prior to 2018, state jurisdictions prior to 2022, and foreign jurisdictions prior to 2020, with a few exceptions.
A reconciliation of the beginning and ending amount of unrecognized tax benefits for the years ended December 31, 2025, 2024 and 2023 is as follows (dollars in millions):
  
Total Unrecognized Tax Benefits
 202520242023
Beginning balance, January 1$33 $33 $36 
Additions for tax positions of prior years
Reductions for tax positions of prior years(6)(9)(15)
Additions for tax positions of current year
Ending balance, December 31$37 $33 $33 
The Company recognized minimal interest expense (benefit) associated with uncertain tax positions in 2025, 2024 and 2023. As of December 31, 2025 and 2024, the Company had $3 million of accrued interest related to unrecognized tax benefits. There are no penalties accrued as of December 31, 2025 or 2024.

Historical Timeline

Fiscal YearFiled
2025Feb 20, 2026Showing above
2024Feb 21, 2025
2022Feb 24, 2023

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.