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Income Taxes
12 Months Ended
Dec. 31, 2019
Income Tax Disclosure [Abstract]  
Income Taxes

9. Income Taxes

The following table presents income tax expense (benefit) for 2019, 2018 and 2017:

 

 

 

Federal

 

 

State

 

 

Foreign

 

 

Total

 

 

 

($ in millions)

 

Year ended December 31, 2019

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Current

 

$

87.9

 

 

$

12.0

 

 

$

70.8

 

 

$

170.7

 

Deferred

 

 

62.9

 

 

 

0.5

 

 

 

(0.7

)

 

 

62.7

 

 

 

$

150.8

 

 

$

12.5

 

 

$

70.1

 

 

$

233.4

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Year ended December 31, 2018

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Current

 

$

(83.3

)

 

$

5.6

 

 

$

32.0

 

 

$

(45.7

)

Deferred

 

 

29.9

 

 

 

0.9

 

 

 

(0.1

)

 

 

30.7

 

 

 

$

(53.4

)

 

$

6.5

 

 

$

31.9

 

 

$

(15.0

)

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Year ended December 31, 2017

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Current

 

$

(41.3

)

 

$

2.7

 

 

$

41.0

 

 

$

2.4

 

Deferred

 

 

(66.6

)

 

 

0.6

 

 

 

(0.2

)

 

 

(66.2

)

 

 

$

(107.9

)

 

$

3.3

 

 

$

40.8

 

 

$

(63.8

)

 

Earnings (losses) before income taxes from domestic operations were $952.4 million, ($46.4) million and ($132.7) million in 2019, 2018 and 2017, respectively. Earnings before income taxes from foreign operations were $171.2 million, $86.0 million and $169.4 million in 2019, 2018 and 2017, respectively. Foreign tax expense was primarily attributable to the U.K., Canada, Switzerland and France.

The following table presents the difference between the federal income tax rate and the effective income tax rate:

 

 

 

Year Ended December 31,

 

 

 

2019

 

 

2018

 

 

2017

 

Federal income tax rate

 

 

21.0

%

 

 

21.0

%

 

 

35.0

%

Foreign tax credits

 

 

0.4

 

 

 

(0.3

)

 

 

(6.4

)

Income subject to dividends-received deduction

 

 

(0.3

)

 

 

(18.3

)

 

 

(25.5

)

Tax-exempt interest

 

 

(1.0

)

 

 

(36.0

)

 

 

(94.1

)

State taxes, net of federal tax benefit

 

 

0.9

 

 

 

13.8

 

 

 

6.5

 

Prior period adjustment

 

 

0.2

 

 

 

(0.1

)

 

 

(3.3

)

Tax benefit from sale of subsidiary

 

 

 

 

 

 

 

 

(54.1

)

Other, net

 

 

(0.4

)

 

 

(18.1

)

 

 

(32.0

)

Effective tax rate

 

 

20.8

%

 

 

(38.0

)%

 

 

(173.9

)%

 

The Tax Act was signed into law on December 22, 2017. Among other provisions, the Tax Act reduced the corporate federal income tax rate from 35.0 percent to 21.0 percent, effective January 1, 2018, for the 2018 and subsequent tax years. As a result, the value of Alleghany’s deferred tax assets and liabilities as of December 31, 2017 was reduced. Alleghany has reflected the impact of the Tax Act in its financial statements. The net impact of this reduction to Alleghany’s consolidated 2017 tax expense was not material.

The increase in effective tax rate in 2019 compared with 2018 primarily reflects the impact of higher earnings before income taxes and, to a lesser extent, lower tax-exempt interest income arising from municipal bond securities and lower dividends-received deductions, partially offset by higher state income taxes.

The decrease in the effective tax rate in 2018 from 2017 primarily reflects the decrease in the U.S. corporate federal income tax rate due to the Tax Act, as well as new limitations on certain deductions as a result of the Tax Act and a tax benefit associated with the sale of PacificComp.

The following table presents the tax effects of temporary differences that give rise to the deferred tax assets and deferred tax liabilities as of December 31, 2019 and 2018:

 

 

 

As of December 31,

 

 

 

2019

 

 

2018

 

 

 

($ in millions)

 

Deferred tax assets:

 

 

 

 

 

 

 

 

Loss and LAE reserves

 

$

118.9

 

 

$

122.9

 

Minimum tax credit carry forward

 

 

 

 

 

68.8

 

Compensation accruals

 

 

94.1

 

 

 

88.1

 

Unearned premiums

 

 

97.4

 

 

 

85.9

 

OTTI losses

 

 

6.5

 

 

 

5.4

 

State net operating loss carry forward

 

 

22.8

 

 

 

23.5

 

Other

 

 

134.9

 

 

 

89.8

 

Gross deferred tax assets before valuation allowance

 

 

474.6

 

 

 

484.4

 

Valuation allowance

 

 

(22.8

)

 

 

(23.5

)

Gross deferred tax assets

 

 

451.8

 

 

 

460.9

 

 

 

 

 

 

 

 

 

 

Deferred tax liabilities:

 

 

 

 

 

 

 

 

Net unrealized gains on investments

 

 

274.8

 

 

 

127.2

 

Deferred acquisition costs

 

 

113.4

 

 

 

101.1

 

Purchase accounting adjustments

 

 

11.7

 

 

 

11.3

 

Other

 

 

46.0

 

 

 

56.4

 

Gross deferred tax liabilities

 

 

445.9

 

 

 

296.0

 

 

 

 

 

 

 

 

 

 

Net deferred tax assets

 

$

5.9

 

 

$

164.9

 

 

Other deferred tax assets include significant amounts of foreign tax credit carry forwards, which begin to expire in 2028. A valuation allowance is provided against deferred tax assets when, in the opinion of management, it is more likely than not that a portion of the deferred tax asset will not be realized. As of December 31, 2019 and 2018, Alleghany recognized $22.8 million and

$23.5 million, respectively, of deferred tax assets for certain state net operating and capital loss carryovers, and a valuation allowance of $22.8 million and $23.5  million, respectively, has been established against these deferred tax assets as Alleghany does not currently anticipate it will generate sufficient income in these states to absorb such loss carryovers.

Alleghany’s income tax return is currently under examination by the Internal Revenue Service for the 2015, 2016 and 2017 tax years. The following table presents the tax years of Alleghany and TransRe tax returns that remain subject to examination by major tax jurisdictions as of December 31, 2019.

 

Major Tax Jurisdiction

 

Open Tax Years

Australia

 

2015-2019

Canada

 

2015-2019

France

 

2017-2019

Germany

 

2013-2019

Hong Kong

 

2013-2019

Japan

 

2019

Singapore

 

2016-2019

Switzerland

 

2017-2019

U.K.

 

2017-2019

U.S.

 

2015-2019

 

Alleghany believes that, as of December 31, 2019, it had no material uncertain tax positions. Interest and penalties related to unrecognized tax expenses (benefits) are recognized in income tax expense, when applicable. There were no material liabilities for interest or penalties accrued as of December 31, 2019.