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Income Taxes
12 Months Ended
Dec. 31, 2017
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes

For the years ended December 31, 2017 and 2016, the Company qualified to be taxed as a REIT under Code Sections 856 through 860. As a REIT, the Company is not subject to federal income tax to the extent that it makes qualifying distributions of taxable income to its stockholders. To maintain qualification as a REIT, the Company must distribute at least 90% of its annual REIT taxable income to its shareholders and meet certain other requirements such as assets it may hold, income it may generate and its shareholder composition. It is generally the Company’s policy to distribute to its shareholders all of the Company’s taxable income.

The state and local tax jurisdictions to which the Company is subject to tax-filing obligations, recognize the Company’s status as a REIT, and therefore, the Company generally does not pay income tax in such jurisdictions. The Company may, however, be subject to certain minimum state and local tax filing fees and its TRSs are subject to federal, state and local taxes. There were no significant income tax expenses for the years ended December 31, 2017, 2016, and 2015.

On December 22, 2017, H.R.1, informally known as the Tax Cuts and Jobs Act (the "TCJA"), was enacted that included, among other items, a reduction in the U.S. federal corporate income tax rate from 35% to 21% effective January 1, 2018. Under generally accepted accounting principles, the Company is required to recognize the effect of this rate change in its deferred tax assets and liabilities in the period the tax rate change is enacted. The Company recorded a deferred tax asset of $4 million and $5 million for the years ended December 31, 2017 and 2016, respectively, relating to activities of its TRSs. Of these amounts, the amount related to cumulative net operating losses was $1 million and $2 million as of December 31, 2017 and 2016, respectively, and the amount related to losses which were disallowed under Code Section 267(a) was $3 million as of December 31, 2017 and 2016. The Company evaluates, based on both positive and negative evidence, the likelihood of realizing its deferred tax assets and established a valuation allowance of $4 million and $5 million for the years ended December 31, 2017 and 2016. We continue to analyze and monitor the application of TCJA to our business.

In general, cash dividends declared by the Company will be considered ordinary income to stockholders for income tax purposes. From time to time, a portion of the Company’s dividends may be characterized as capital gains or return of capital distributions.

The Company’s effective tax rate differs from its combined federal, state and city corporate statutory tax rate primarily due to the deduction of dividend distributions required to be paid under Code Section 857(a).

The Company’s 2016, 2015 and 2014 federal, state and local tax returns remain open for examination.