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Income Taxes
6 Months Ended
Jun. 30, 2015
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes

It is our general policy to estimate taxes for interim periods based on estimated annual effective tax rates which are derived, in part, from expected annual pre-tax income. However, the change in the deferred income tax asset balances, income tax benefit and expense and related valuation allowance for the three and six months ended June 30, 2015 have been computed based on the first six months of 2015 as a discrete period.
The tax benefit of $89.8 million for the three months ended June 30, 2015 is comprised of a $90.6 million current tax benefit and a $0.8 million deferred tax expense. The tax benefit of $87.0 million for the six months ended June 30, 2015 is attributable to current tax benefits, primarily from the tax benefit on the ceding commission associated with the intercompany reinsurance transaction. See Note 11 to these consolidated interim unaudited financial statements. Of the current tax benefit, $0.8 million is a result of the conclusion of the 2011 and 2012 IRS audit. The remaining $86.2 million current tax benefit represents a benefit on our six month ended taxable loss.

We recorded a deferred tax asset, net of deferred tax liabilities and valuation allowances, of $24.4 million as of June 30, 2015. Consistent with prior periods, we have recorded a full valuation allowance against all categories of net deferred tax assets other than gross unrealized losses on available-for-sale debt securities, due to the significant negative evidence of historical cumulative U.S. GAAP losses and the uncertainty of consistent future U.S. GAAP earnings.

We have concluded that a valuation allowance on the deferred tax assets attributable to available-for-sale debt securities with gross unrealized losses was not required due to our ability and intent to hold these securities until recovery of fair value or contractual maturity, thereby avoiding realization of taxable capital losses. This conclusion is consistent with prior periods.

Consistent with the above, for the three and six months ended June 30, 2015, we recognized a net decrease in the valuation allowance of $83.0 million and $60.0 million, respectively. In accordance with the intraperiod tax allocation rules, the change in the valuation allowance has been allocated to various financial statement components of income or loss. The net deferred tax assets increased by $13.5 million for the three months ended June 30, 2015, which was attributable to available-for-sale debt securities with gross unrealized losses. The net deferred tax assets increased by $11.3 million for the six months ended June 30, 2015, which also was attributable to available-for-sale debt securities with gross unrealized losses.

The Company is included in Phoenix’s consolidated, combined, unitary or separate income tax returns in the U.S. federal, various state and foreign jurisdictions. In the second quarter of 2015, the IRS concluded their IRS audit of tax years 2011 and 2012, resulting in a benefit of $0.8 million. The Company is no longer subject to U.S. federal income tax examinations by tax authorities for years before 2013.

Based upon the timing and status of our current examinations by taxing authorities, we do not believe that it is reasonably possible that any changes to the balance of unrecognized tax benefits occurring within the next 12 months will result in a significant change to the results of operations, financial condition or liquidity. In addition, we do not anticipate that there will be additional payments made or refunds received within the next 12 months with respect to the years under audit. We do not anticipate any increases to the existing unrecognized tax benefits that would have a significant impact on the financial position of the Company.