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 (expense) benefit from the statutory income tax rate to the effective tax rate based on our loss before income taxes for the years ended December 31, 2025, 2024, and 2023 is as follows (in thousands):


	For the Years Ended December 31,
	2025*						2024			2023
	Amount			Percent			Amount			Amount
Loss before income tax	$	(237,319	)		100.0	%	$	(2,364,186	)	$	(686,771	)
Income tax benefit at the U.S. statutory federal rate		49,837			21.0	%		496,479			144,222
State and local income tax, net of federal income tax effect		—			—			—			1,275
Foreign tax effects:
U.K.:
Statutory tax rate difference between U.K. and U.S.		4,193			1.8	%		—			—
Changes in valuation allowances		(10,222	)		(4.3	)%		—			—
Tax impact of U.K. REIT conversion		—			—			—			160,641
Other		1,227			0.5	%		—			—
Colombia:
Statutory tax rate difference between Colombia and U.S.		3,826			1.6	%		—			—
Changes in valuation allowances		(9,954	)		(4.2	)%		—			—
Other		(1,713	)		(0.7	)%		—			—
Other foreign jurisdictions		(3,210	)		(1.4	)%		—			—
Foreign rate differential		—			—			4,888			(4,122	)
Interest disallowance		—			—			(2,965	)		(3,421	)
Changes in valuation allowances		(46,033	)		(19.4	)%		(301,468	)		(45,692	)
Nontaxable or nondeductible items:
U.S. earnings not subject to federal income tax		(26,569	)		(11.2	)%		(227,080	)		(115,189	)
Other adjustments		—			—			(13,955	)		(7,035	)
Total income tax (expense) benefit/effective tax rate	$	(38,618	)		(16.3	)%	$	(44,101	)	$	130,679

*Above is a reconciliation of the U.S. federal statutory income tax rate to our effective tax rate pursuant to the disclosure requirements of ASU 2023-09, "Income Taxes (Topic 740): Improvements to Income Tax Disclosures" ("ASU 2023-09"), for the year ended December 31, 2025. As allowed by ASU 2023-09, the 2024 and 2023 columns have not been restated to conform to the 2025 presentation.

Schedule of Deferred Tax Assets and Liabilities

Deferred Income Taxes

At December 31, 2025 and 2024, components of our deferred tax assets and liabilities were as follows (in thousands):


	2025			2024
Deferred tax assets:
Operating loss and interest deduction carryforwards	$	334,501		$	263,523
Depreciation		70,051			56,089
Partnership investments		143,695			112,892
Impairment and other loss reserves		66,969			101,834
Other		10,263			8,500
Total deferred tax assets		625,479			542,838
Valuation allowance		(489,604	)		(418,659	)
Total net deferred tax assets	$	135,875		$	124,179
Deferred tax liabilities:
Property and equipment	$	(149,602	)	$	(145,835	)
Net unbilled revenue		(106,088	)		(82,170	)
Partnership investments		(26,885	)		(21,445	)
Other		(4,102	)		(3,450	)
Total deferred tax liabilities		(286,677	)		(252,900	)
Net deferred tax asset (liability)	$	(150,802	)	$	(128,721	)

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:	2025			2024		2023
Ordinary dividend (1)	$	—		$	—	$	1.0639
Long-term capital gain (2)		—			—		0.1061
Return of capital		0.3200			0.3800		—
Total	$	0.3200	(3)	$	0.3800	$	1.1700

(1)

For the year ended December 31, 2023, includes Section 199A dividends of 1.0639.

(2)

For the year ended December 31, 2023, includes Unrecaptured Section 1250 gains of 0.1061.

(3)

The dividend declared on November 17, 2025 and paid January 8, 2026 will be applicable to the 2026 tax year and thus is not reflected in the table above.