Income Taxes

The following table summarizes dividends for federal income tax purposes declared for fiscal years 2012, 2011 and 2010 and their related tax characterization (in millions, except per share amounts):



					Tax Characterization
Fiscal Tax Year	Dividends Declared Per Share		Dividends Declared		Ordinary Income Per Share		Long-Term Capital Gains Per Share
Series A Cumulative Redeemable Preferred Stock Dividends
Fiscal year 2012 ⁽¹⁾	$	1.056	$	7	$	0.9523	$	0.1037
Common Stock Dividends
Fiscal year 2012	$	5.00	$	1,518	$	4.5092	$	0.4908
Fiscal year 2011	$	5.60	$	886	$	5.3324	$	0.2676
Fiscal year 2010	$	5.60	$	230	$	4.9314	$	0.6686

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1.	Excludes preferred stock dividend of $0.50 per share declared on December 17, 2012 having a record date of January 1, 2013, which for federal income tax purposes is a fiscal year 2013 dividend.

As of December 31, 2012, we had approximately $749 million of estimated undistributed taxable income that we expect to declare by the extended due date of our 2012 federal income tax return and pay in 2013. Accordingly, we do not expect to incur any income tax liability on our 2012 taxable income.

For fiscal years 2012 and 2011, we did not distribute the required minimum amount of taxable income pursuant to federal excise tax requirements, as described in Note 2, and consequently we accrued an excise tax of $25 million and $2 million, respectively, which is included in our net income tax provision on our accompanying consolidated statements of operations and comprehensive income.

For fiscal years 2012 and 2011, we recorded an income tax benefit of $6 million and an income tax provision of $4 million, respectively, attributable to our TRS, which is included in our net income tax provision on our accompanying consolidated statements of comprehensive income. The statutory combined federal and state corporate tax rate for our TRS was 39.5% for fiscal years 2012 and 2011. For the fiscal year 2010 we had no activity in our TRS.

Based on our analysis of any potential uncertain income tax positions, we concluded that we do not have any uncertain tax positions that meet the recognition or measurement criteria of ASC 740 as of December 31, 2012, 2011 and 2010. Our tax returns for tax years 2008 through 2012 are open to examination by the IRS. In the event that we incur income tax related interest and penalties, our policy is to classify them as a component of provision for income taxes.