Income Taxes (Tables)

12 Months Ended

Dec. 31, 2023

Income Tax Disclosure [Abstract]

Schedule of Income Tax Benefit (Expense)

From our TRS entities and our foreign operations, income tax benefit (expense) were as follows (in thousands):

	For the Years Ended December 31,
	2023			2022			2021
Current income tax (expense) benefit:
Domestic	$	(7,756	)	$	1,111		$	(1,559	)
Foreign		(24,257	)		(27,751	)		(18,964	)
		(32,013	)		(26,640	)		(20,523	)
Deferred income tax (expense) benefit:
Domestic		8,926			(15,628	)		6,915
Foreign		153,766			(13,632	)		(60,340	)
		162,692			(29,260	)		(53,425	)
Income tax benefit (expense)	$	130,679		$	(55,900	)	$	(73,948	)

Summary of Reconciliation of Income Tax Benefit (Expense) from the Statutory Income Tax Rate to the Effective Tax Rate Based on Income before Income Taxes

A reconciliation of income tax benefit (expense) from the statutory income tax rate to the effective tax rate based on (loss) income before income taxes for the years ended December 31, 2023, 2022, and 2021 is as follows (in thousands):

	For the Years Ended December 31,
	2023			2022			2021
(Loss) income before income tax	$	(686,771	)	$	959,719		$	730,888
Income tax benefit (expense) at the U.S. statutory federal rate (21% in 2023, 2022, and 2021)		144,222			(201,541	)		(153,486	)
Decrease (increase) in income tax resulting from:
Foreign rate differential		(4,122	)		1,826			2,742
State income taxes, net of federal benefit		1,275			(1,886	)		—
U.S. earnings not subject to federal income tax		(115,189	)		165,705			132,266
Change in valuation allowance		(45,692	)		(11,281	)		(10,040	)
Statutory tax rate change		—			(941	)		(43,924	)
Interest disallowance		(3,421	)		(1,737	)		(646	)
Tax Impact of UK REIT conversion		160,641			—			—
Other items, net		(7,035	)		(6,045	)		(860	)
Total income tax benefit (expense)	$	130,679		$	(55,900	)	$	(73,948	)

Schedule of Deferred Tax Assets and Liabilities

At December 31, 2023 and 2022, components of our deferred tax assets and liabilities were as follows (in thousands):

	2023			2022
Deferred tax assets:
Operating loss and interest deduction carry forwards	$	143,683		$	175,922
Depreciation		45,146			—
Partnership investments		15,768			—
Other		18,899			15,218
Total deferred tax assets		223,496			191,140
Valuation allowance		(117,191	)		(71,499	)
Total net deferred tax assets	$	106,305		$	119,641
Deferred tax liabilities:
Property and equipment	$	(158,330	)	$	(294,181	)
Net unbilled revenue		(65,727	)		(63,324	)
Partnership investments		—			(26,268	)
Other		(10,687	)		(27,153	)
Total deferred tax liabilities		(234,744	)		(410,926	)
Net deferred tax asset (liability)	$	(128,439	)	$	(291,285	)

Schedule of Net NOL and Other Tax Attribute Carryforwards

At December 31, 2023, we had net NOL and other tax attribute carryforwards as follows (in thousands):

	U.S.			Foreign
Gross NOL carryforwards	$	169,970		$	458,913
Tax-effected NOL carryforwards	$	28,056		$	114,359
Valuation allowance		(27,956	)		(4,702	)
Net deferred tax asset - NOL carryforwards	$	100		$	109,657
Expiration periods	2024-indefinite			indefinite

Schedule of Per Share Distributions to Stockholders

A schedule of per share distributions we paid and reported to our stockholders is set forth in the following:

	For the Years Ended December 31,
Per share:	2023			2022		2021
Ordinary dividend (1)	$	1.0639		$	0.4703	$	0.7646
Long-term capital gain (2)		0.1061			0.6797		0.1654
Return of capital		—			—		0.1800
Total	$	1.1700	(3)	$	1.1500	$	1.1100

(1)For the years ended December 31, 2023, 2022, and 2021, includes Section 199A dividends of 1.0639, 0.4703, and 0.7646, respectively.

(2)For the years ended December 31, 2023, 2022, and 2021, includes Unrecaptured Section 1250 gains of 0.1061, 0.2574, and 0.0583, respectively.

(3)Includes the fourth quarter dividend declared on November 9, 2023, and paid on January 11, 2024, as it will be taxable to stockholders as part of their 2023 dividend income.