Income Taxes

For federal income tax purposes, the cash distributions paid for the years ended December 31, 2014 and 2013 are characterized as follows:



	For the Years Ended December 31,
	2014		2013
Common distributions
Ordinary income	100.0	%	100.0	%
Return of capital	—		—
Capital gains	—		—
	100.0	%	100.0	%

The components of the income tax provision from continuing operations are as follows (in thousands):



	For the Years Ended December 31,
	2014			2013			2012
Current:
Federal	$	(244	)	$	(323	)	$	(50	)
State	(1,543		)	(1,439		)	(1,381		)
Deferred:
Federal	572			830			64
State	70			53			(2		)
Total net tax expense	$	(1,145	)	$	(879	)	$	(1,369	)

The provision for income taxes differs from the amount of income tax determined by applying the applicable U.S. statutory federal income tax rate to pretax income from continuing operations for the years ended December 31, 2014, 2013 and 2012 as a result of the following differences (in thousands):



	For the Years Ended December 31,
	2014			2013			2012
Expected federal tax expense at statutory rate	$	(47,906	)	$	(40,271	)	$	(14,952	)
Tax impact of REIT election	45,842			37,230			22,618
Expected tax (expense) benefit at TRS	(2,064		)	(3,041		)	7,666
Change in valuation allowance	2,203			3,612			(8,741		)
State income (expense) benefit, net of federal tax benefit	(1,273		)	(1,345		)	595
Impact of rate change	42			(94		)	146
Other permanent items	(418		)	(443		)	(394		)
Impact of acquired tax attributes	(5		)	361			(361		)
Impact of provision to return	370			71			(280		)
Income tax expense	$	(1,145	)	$	(879	)	$	(1,369	)

Deferred income taxes represent the tax effect from continuing operations of the differences between the book and tax basis of assets and liabilities. Deferred tax assets (liabilities) include the following (in thousands):



	December 31,
	2014			2013
Deferred tax liabilities:
Property and equipment	$	(5,354	)	$	(1,787	)
Prepaid expenses	(2,362		)	(1,662		)
Other - deferred tax liabilities	(163		)	(99		)
Deferred tax liabilities	$	(7,879	)	$	(3,548	)

Deferred tax assets:
Property and equipment	$	—		$	515
Deferred revenue - key money	1,429			1,478
Incentive and vacation accrual	2,627			2,325
Allowance for doubtful accounts	65			92
Other - deferred tax assets	191			285
Other carryforwards	158			106
Net operating loss carryforwards	54,355			51,254
Valuation allowance	(51,323		)	(53,526		)
Deferred tax assets	$	7,502		$	2,529

The Company recorded a valuation allowance of approximately $51.3 million and $53.5 million related to its net operating loss, or NOL, carryforwards and other deferred tax assets at December 31, 2014 and 2013, respectively, as the Company believed it was more likely than not that it would not realize the benefits associated with these NOLs and other deferred tax assets. The ability to carry forward the tax benefit of NOLs of approximately $54.4 million will begin to expire in 2026 for federal tax purposes and during the period from 2016 to 2026 for state tax purposes if not utilized. The Company’s TRS entities experienced a change of control as defined in Section 382 of the Code, the TRS’s ability to utilize NOLs in the years after the change in control will be limited.

The Company owns subsidiary TRSs which are not part of a consolidated tax return, these deferred tax assets and liabilities are presented on a combined basis and are not subject to a valuation allowance.

The net current and non-current components of deferred income taxes included in the consolidated balance sheets are as follows (in thousands):



	December 31,
	2014			2013
Current net deferred tax assets	$	616		$	263
Current net deferred tax liabilities	(2,524		)	(1,761		)
Non-current net deferred tax assets	6,886			2,266
Non-current net deferred tax liabilities	(5,355		)	(1,787		)
Net deferred tax liability	$	(377	)	$	(1,019	)

The Company had no accruals for tax uncertainties as of December 31, 2014 and December 31, 2013.