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Income Taxes
3 Months Ended
Mar. 31, 2022
Income Tax Disclosure [Abstract]  
Income Taxes
Note 13 - Income Taxes
The following table reconciles our GAAP net income (loss) to estimated REIT taxable loss for the three months ended March 31, 2022 and March 31, 2021.
 For the Three Months Ended March 31,
 20222021
GAAP net income (loss)$(66,434)$71,327 
Book to tax differences:
TRS income(1)(7)
Premium amortization expense(41)(48)
Agency Securities, trading254,389 62,586 
U.S. Treasury Securities78,387 28 
Changes in interest rate contracts(250,900)(122,195)
Gain on Security Sales— (7,354)
Amortization of deferred hedging costs(39,581)(41,867)
Other550 417 
Estimated REIT taxable loss$(23,631)$(37,113)
Interest rate contracts and futures contracts are treated as hedging transactions for U.S. federal income tax purposes. Unrealized gains and losses on open interest rate contracts are not included in the determination of REIT taxable income. Realized gains and losses on interest rate contracts terminated before their maturity are deferred and amortized over the remainder of the original term of the contract for REIT taxable income. At March 31, 2022 and at December 31, 2021, we had approximately $567,419 and $607,000 in tax deductible expense relating to previously terminated interest rate swap contracts amortizing through the year 2031. At March 31, 2022, we had $240,428 of net operating loss carryforwards available for use indefinitely.
Net capital losses realizedAmountAvailable to offset capital gains through
2018$(136,388)2023
2019$(13,819)2024
2021$(15,605)2026
The Company's subsidiary, ARMOUR TRS, Inc. has made an election as a taxable REIT subsidiary (“TRS”). As such, the TRS is taxable as a domestic C corporation and subject to federal, state, and local income taxes based upon its taxable income.
The aggregate tax basis of our assets and liabilities was less than our total Stockholders’ Equity at March 31, 2022 by approximately $308,578, or approximately $3.07 per common share (based on the 100,361 common shares then outstanding). State and federal tax returns for the years 2018 and later remain open and are subject to possible examination.
We are required and intend to timely distribute substantially all of our REIT taxable income in order to maintain our REIT status under the Code. Total dividend payments to stockholders for the three months ended March 31, 2022 and March 31, 2021 were $32,103 and $22,543, respectively.
Our REIT taxable income and dividend requirements to maintain our REIT status are determined on an annual basis. Dividends paid in excess of current tax earnings and profits for the year will generally not be taxable to common stockholders.
Our management is responsible for determining whether tax positions taken by us are more likely than not to be sustained on their merits. We have no material unrecognized tax benefits or material uncertain tax positions.