INCOME TAX
Pre-tax income for the years ended December 31, 2025, 2024 and 2023 consists of the following (dollars in millions):
| | | | | | | | | | | | | | | | | | | | |
| | 2025 | | 2024 | | 2023 |
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):
| | | | | | | | | | | | | | | | | | | | |
| | | 2025 | | 2024 | | 2023 |
| Current income tax expense (benefit): | | | | | | |
| U.S. federal | | $ | 196 | | | $ | 148 | | | $ | (20) | |
| U.S. state | | 2 | | | 2 | | | 2 | |
| Foreign | | (187) | | | 167 | | | 58 | |
| Total current | | 11 | | | 317 | | | 40 | |
| Deferred income tax expense (benefit): | | | | | | |
| U.S. federal | | (13) | | | (129) | | | 236 | |
| U.S. state | | — | | | — | | | — | |
| Foreign | | 353 | | | 68 | | | (25) | |
| Total deferred | | 340 | | | (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) | | 2 | | | 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 reorganization | | 27 | | | 1.8 | | | | | |
| Canada | | 28 | | | 1.8 | | | | | |
| Other foreign jurisdictions | | (13) | | | (0.8) | | | | | |
| | | | | | | | |
| Effect of Cross-Border Tax Laws | | | | | | | | |
| Subpart F income, net of credits | | (33) | | | (2.2) | | | | | |
| Other | | 6 | | | 0.4 | | | | | |
| | | | | | | | |
| | | | | | | | |
| | | | | | | | |
| Changes in Valuation Allowance | | 1 | | | 0.1 | | | | | |
| Nontaxable or Nondeductible Items | | (8) | | | (0.5) | | | | | |
| Changes in Unrecognized Tax Benefits | | 3 | | | 0.2 | | | | | |
| Other Reconciling Items | | | | | | | | |
| Legal entity restructuring | | 49 | | | 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):
| | | | | | | | | | | | | | |
| | 2024 | | 2023 |
| Tax provision at U.S. statutory rate | | $ | 206 | | | $ | 244 | |
| Increase (decrease) in income taxes resulting from: | | | | |
| Tax rate differences on income in other jurisdictions | | 44 | | | 14 | |
| Differences in tax basis in foreign jurisdictions | | (18) | | | 4 | |
| Deferred tax valuation allowance | | (5) | | | 15 | |
| Amounts related to uncertain tax positions | | 2 | | | (2) | |
| Compensation | | 1 | | | 2 | |
| Corporate rate changes | | (4) | | | — | |
| GILTI, net of credits | | 14 | | | — | |
| Subpart F for non-full inclusion companies | | 26 | | | 28 | |
| Foreign tax credits | | (5) | | | (42) | |
| Return to provision and amended adjustments | | (17) | | | (9) | |
| Pillar II | | 5 | | | — | |
| Effects of tax law changes and legal entity restructuring | | 9 | | | — | |
| 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):
| | | | | | | | | | | | | | | | | | | | |
| | 2025 | | 2024 | | 2023 |
| 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 benefits | | 564 | | | 586 | | | (161) | |
| Market risk benefits | | — | | | — | | | (3) | |
| Foreign currency translation | | (17) | | | 32 | | | 22 | |
| | | | | | |
| Unrealized pension and postretirement | | 4 | | | 2 | | | (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):
| | | | | | | | | | | | | | |
| | | 2025 | | 2024 |
| Deferred income tax assets: | | | | |
| Nondeductible accruals | | $ | 85 | | | $ | 102 | |
| Net operating loss carryforward | | 829 | | | 846 | |
| | | | |
| | | | |
| Capital loss carryforwards | | 3 | | | 92 | |
| Tax credit carryforward | | 133 | | | 220 | |
| Invested assets | | 1,621 | | | 1,407 | |
| Anticipated future foreign tax credit | | 511 | | | 442 | |
| | | | |
| Subtotal | | 3,182 | | | 3,109 | |
| Valuation allowance | | (726) | | | (678) | |
| Total deferred income tax assets | | 2,456 | | | 2,431 | |
| Deferred income tax liabilities: | | | | |
| Deferred acquisition costs | | 644 | | | 931 | |
| Policy reserves and other reinsurance liabilities | | 4,569 | | | 3,428 | |
| Foreign currency translation | | 162 | | | 190 | |
| Anticipated future foreign tax credit reduction | | — | | | — | |
| Other | | 1 | | | 3 | |
| Total deferred income tax liabilities | | 5,376 | | | 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 payable | | 28 | | | — | |
| 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 local | | 1 | |
| Total U.S. | | $ | 50 | | |
| Foreign | | | |
| Canada | | 127 | | |
| Hong Kong | | 31 | | |
| | | |
| Japan | | 20 | | |
| All Other | | 24 | | |
| 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 allowance | 232 | |
| NOL with no expiration and a partial valuation allowance | 500 | |
| 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 |
| | | 2025 | | 2024 | | 2023 |
| Beginning balance, January 1 | | $ | 33 | | | $ | 33 | | | $ | 36 | |
| | | | | | |
| Additions for tax positions of prior years | | 5 | | | 2 | | | 9 | |
| Reductions for tax positions of prior years | | (6) | | | (9) | | | (15) | |
| Additions for tax positions of current year | | 5 | | | 7 | | | 3 | |
| | | | | | |
| | | | | | |
| 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.