We have maintained and intend to maintain our election as a REIT under the Code. To qualify as a REIT, we must meet a number of organizational and operational requirements, including a requirement to distribute at least 90% of our taxable income to our stockholders. As a REIT, we generally will not be subject to U.S. federal income tax if we distribute 100% of our taxable income to our stockholders and satisfy certain other requirements; instead, income tax is paid directly by our stockholders on the dividends distributed to them. If our taxable income exceeds our dividends in a tax year, REIT tax rules allow us to designate dividends from the subsequent tax year in order to avoid current taxation on undistributed income. If we fail to qualify as a REIT in any taxable year, we will be subject to federal income taxes at regular corporate rates, including any applicable alternative minimum tax. Taxable income from non-REIT activities managed through our TRS is subject to applicable U.S. federal, state, and local income taxes. Our international subsidiaries are also subject to income taxes in the jurisdictions in which they operate.

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

	For the Years Ended December 31,
	2020			2019			2018
Current income tax benefit (expense):
Domestic	$	63		$	61		$	125
Foreign		(10,203	)		(1,669	)		(3,294	)
		(10,140	)		(1,608	)		(3,169	)
Deferred income tax benefit (expense):
Domestic		(10,680	)		5,490			3,713
Foreign		(10,236	)		(1,261	)		(1,471	)
		(20,916	)		4,229			2,242
Income tax benefit (expense)	$	(31,056	)	$	2,621		$	(927	)

A reconciliation of income tax benefit (expense) from the statutory income tax rate to the effective tax rate based on income before income taxes for the years ended December 31, 2020, 2019, and 2018 is as follows (in thousands):

	For the Years Ended December 31,
	2020			2019			2018
Income before income tax	$	463,328		$	373,780		$	1,019,404
Income tax at the U.S. statutory federal rate (21% in 2020, 2019 and 2018)		(97,299	)		(78,494	)		(214,075	)
Decrease (increase) in income tax resulting from:
Foreign rate differential		2,160			438			2,643
State income taxes, net of federal benefit		970			1,621			(379	)
U.S. earnings not subject to federal income tax		82,921			85,495			208,472
Equity investments		380			1,091			46
Change in valuation allowance		(8,514	)		(7,911	)		2,668
Statutory tax rate change		(9,471	)		—			—
Other items, net		(2,203	)		381			(302	)
Total income tax benefit (expense)	$	(31,056	)	$	2,621		$	(927	)

The foreign provision for income taxes is based on foreign profit before income taxes of $62.1 million, $10.7 million, and $18.6 million in 2020, 2019, and 2018, respectively.

The domestic provision for income taxes is based on income before income taxes of $6.4 million in 2020 as compared with a loss before income taxes of $(44.1) million in 2019 from our TRS and income before income taxes of $8.0 million in 2018.

At December 31, 2020 and 2019, components of our deferred tax assets and liabilities were as follows (in thousands):

	2020			2019
Deferred tax assets:
Operating loss and interest deduction carry forwards	$	150,001		$	28,684
Interest rate swap		9,150			843
Other		6,973			868
Total deferred tax assets		166,124			30,395
Valuation allowance		(36,977	)		(11,355	)
Total net deferred tax assets	$	129,147		$	19,040
Deferred tax liabilities:
Property and equipment	$	(211,018	)	$	(7,324	)
Net unbilled revenue		(14,776	)		(1,449	)
Other		(4,010	)		(737	)
Total deferred tax liabilities		(229,804	)		(9,510	)
Net deferred tax asset (liability)	$	(100,657	)	$	9,530

At December 31, 2020, we had net NOL and other tax attribute carryforwards as follows (in thousands):

	U.S.			Foreign
Gross NOL carryforwards	$	159,895		$	528,567

Tax-effected NOL carryforwards	$	16,298		$	133,703
Valuation allowance		(6,193	)		(30,784	)
Net deferred tax asset - NOL carryforwards	$	10,105		$	102,919
Expiration periods	2029-indefinite			indefinite

A valuation allowance has been recorded on certain foreign and domestic net operating loss carryforwards and other net deferred tax assets that may not be realized. As of each reporting date, we consider all new evidence that could impact the future realization of our deferred tax assets. In the evaluation of the need for a valuation allowance on our deferred income tax assets, we consider all available positive and negative evidence, including scheduled reversals of deferred income tax liabilities, carryback of future period losses to prior periods, projected future taxable income, tax planning strategies, and recent financial performance.

During 2020, a valuation allowance of $25.6 million has been recorded against a portion of our international deferred tax assets to recognize only the components of the deferred tax assets that is more likely than not to be realized. The valuation allowance was primarily recorded against deferred tax assets for NOLs, non-depreciable basis of real property, and other tax attributes that we believe will not be realized.

We have no material uncertain tax position liabilities and related interest or penalties.

We have met the annual REIT distribution requirements by payment of at least 90% of our taxable income in 2020, 2019, and 2018. Earnings and profits, which determine the taxability of such distributions, will differ from net income reported for financial reporting purposes due primarily to differences in cost basis, differences in the estimated useful lives used to compute depreciation, and differences between the allocation of our net income and loss for financial reporting purposes and for tax reporting purposes.

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,
	2020		2019		2018
Common share distribution	$	1.070000	$	1.010000	$	0.990000
Ordinary income		0.603050		0.701910		0.438792
Capital gains(1)		—		0.275040		0.551208
Unrecaptured Sec. 1250 gain		—		0.041160		0.132280
Section 199A Dividends		0.603050		0.701910		0.438792
Return of capital		0.466950		0.033050		—

As a partnership, the allocated share of income of the Operating Partnership is included in the income tax returns of the general and limited partners. Accordingly, no accounting for income taxes is generally required for such income of the Operating Partnership. However, the Operating Partnership has formed a TRS on behalf of Medical Properties Trust, Inc., which is subject to U.S. federal, state, and local income taxes at regular corporate rates, and its international subsidiaries are subject to income taxes in the jurisdictions in which they operate. See discussion above under Medical Properties Trust, Inc. for more details of income taxes associated with our TRS and international operations.