Income Taxes |
9 Months Ended |
|---|---|
Sep. 30, 2025 | |
| Income Tax Disclosure [Abstract] | |
| Income Taxes | 11. Income Taxes The Company’s income tax provision totaled $438 million and $317 million for the three months ended September 30, 2025 and 2024, respectively, and totaled $684 million and $1 billion for the nine months ended September 30, 2025 and 2024, respectively. The Company’s effective income tax rate was approximately 15.1% and 15.2% for the three months ended September 30, 2025 and 2024, respectively, and 13.9% and 17.5% for the nine months ended September 30, 2025 and 2024, respectively. Under U.S. GAAP, a tax benefit from an uncertain tax position may be recognized when it is more likely than not that the position will be sustained upon examination, including resolution of any related appeals or litigation, based on the technical merits of the position. As of September 30, 2025, the Company recorded $10 million of unrecognized tax benefits for uncertain tax positions. Approximately all of the unrecognized tax benefits, if recognized, would impact the effective tax rate. The Company does not believe that it has any tax positions for which it is reasonably possible that it will be required to record significant amounts of unrecognized tax benefits within the next twelve months. The primary jurisdictions in which the Company operates and incurs income taxes are the United States, the United Kingdom, and Bermuda. There are no material unremitted earnings with respect to the United Kingdom or other foreign jurisdictions. In the normal course of business, the Company is subject to examination by federal, state, local and foreign tax authorities. As of September 30, 2025, the Company’s U.S. federal, state, local and foreign income tax returns for the years 2021 through 2023 are open under the general statute of limitations provisions and therefore subject to examination. Currently, the Internal Revenue Service is examining the tax returns of the Company and certain subsidiaries for tax years 2019 to 2023. The State and City of New York are examining certain subsidiaries’ tax returns for tax years 2014 to 2023. The United Kingdom tax authorities are currently examining certain subsidiaries’ tax returns for tax years 2015 to 2022. There are other examinations ongoing in other state, local, and foreign jurisdictions in which the Company operates. No provisions with respect to these examinations have been recorded, other than the unrecognized tax benefits discussed above. On June 28, 2025, the Group of Seven (“G7”)—comprising Canada, France, Germany, Italy, Japan, the United Kingdom, and the United States—released a joint statement supporting the exclusion of U.S. parented multinational groups from the Pillar Two Income Inclusion Rule (“IIR”) and Undertaxed Profits Rule (“UTPR”), with respect to both domestic and foreign profits. While such an exclusion would likely apply to the Company’s wholly-owned entities, its applicability to ACRA remains uncertain due to ACRA’s partial ownership by the Company. Additionally, it is unclear whether Bermuda will amend its corporate income tax (“CIT”) regime in response to the G7’s statement. The Company continues to monitor these developments closely. The Company’s financial results continue to reflect the impacts of both Pillar Two and the Bermuda CIT on U.S. and non-U.S. income. Any future changes to either regime could affect the Company’s financial statements. On July 4, 2025, President Donald J. Trump signed into law H.R. 1, the One Big Beautiful Bill Act (the “OBBBA”). The OBBBA includes a broad range of tax reform provisions, including extending and modifying certain key provisions from the Tax Cuts and Jobs Act of 2017 and expanding certain incentives from the Inflation Reduction Act of 2022 while accelerating the phase-out of others. Certain provisions are effective starting in 2025, while others are not effective until 2026. The OBBBA is not currently anticipated to have a material impact on the Company’s income tax provision.
|