INCOME TAXES

12 Months Ended

Dec. 31, 2025

Income Tax Disclosure [Abstract]

INCOME TAXES

INCOME TAXES

The Company elected to be taxed as a REIT for U.S. federal income tax purposes beginning with the taxable year ended December 31, 2014. To maintain REIT status, the Company must meet a number of organizational and operational requirements, including a requirement to distribute at least 90% of its REIT taxable income, determined without regard to the dividends paid deduction and excluding any net capital gains. In addition, the Company is required to meet certain asset and income tests. As a REIT, the Company generally will not be subject to corporate level federal income tax on taxable income that it distributes to its stockholders. The Company also elected to treat certain of its consolidated subsidiaries as taxable REIT subsidiaries, which are subject to federal, state and foreign income taxes. In addition, as a result of our investments in the U.K., the Company is subject to income taxes under the laws of the U.K.

Cash distributions paid to common stockholders for federal income tax purposes are as follows for the periods presented:

	Year Ended December 31,
Common Stock	2025		2024		2023
Ordinary dividend	$	1.2950	$	0.8529	$	0.8218
Non-dividend distributions	—		0.2971		0.2932
Total taxable distribution	1.2950		1.1500		1.1150
Distributions allocated from prior tax year(1)	(0.2900)		(0.2800)		(0.2750)
Distributions allocated to subsequent tax year(1)	0.3350		0.2900		0.2800
Total distributions declared	$	1.3400	$	1.1600	$	1.1200

(1) The dividend distributions made to holders of record as of the end of each year and paid in January of the following year were considered a dividend distribution in the following year for federal income tax purposes.

REITs generally are not subject to U.S. federal income taxes on that portion of REIT taxable income or capital gain that is distributed to stockholders. For the tax year ended December 31, 2025, as a result of ownership of investments in a TRS and the U.K., the Company was subject to federal, state and foreign income taxes under the respective tax laws of these jurisdictions.

The following table summarizes pretax income and income tax expense by geography for continuing operations for the period presented (dollars in thousands):

	For the Year Ended December 31, 2025
	Pretax income		Income tax expense
Domestic	$	316,553	$	19
Foreign	8,734		4,982
Total	$	325,287	$	5,001

The following table summarizes the Company’s income tax expense (benefit) from continuing operations for the period presented (dollars in thousands):

	For the Year Ended December 31, 2025
	Income tax expense
Current - Federal	$	66
Current - State	6
Deferred - Federal	(53)
Deferred - Foreign	4,982
Total income tax expense (benefit)	$	5,001

A reconciliation of income taxes, which is computed by applying the federal corporate tax rate for the year ended December 31, 2025, to the income tax expense (benefit) is as follows for the period presented (in thousands):

	For Year Ended December 31,
	2025
Tax at statutory rate on earnings from continuing operations before, noncontrolling interests and income taxes	$	68,310	21.0	%
Tax at statutory rate on earnings not subject to federal income taxes	(83,602)		(25.7)	%
Other differences	20,293		6.2	%
Totals	$	5,001	1.5	%

Each TRS and foreign entity subject to income taxes is a tax paying component for purposes of classifying deferred tax assets and liabilities. The tax effects of taxable and deductible temporary differences, as well as tax asset and liability attributes, are summarized as follows for the period presented (in thousands):

	As of December 31,
	2025
Deferred tax assets (liabilities):
Foreign net operating loss carryforward	$	1,395
Investment in partnerships	53
Valuation allowance on deferred tax asset	(1,395)
Net deferred tax assets	53
Deferred tax related to investment in foreign subsidiary	(5,558)
Net deferred tax liability	(5,558)
Net deferred tax assets (liabilities)	$	(5,505)

The Company intends to only distribute from its subsidiary UK REIT the minimum amount required to maintain its REIT status in the U.K. The Company intends to indefinitely reinvest the UK REIT’s remaining undistributed earnings and, accordingly, has not recorded a U.S. deferred tax liability related to the withholding tax on those earnings.

The Company has recorded valuation allowances totaling $1.4 million. The Company evaluates its deferred tax assets each period to determine if a valuation allowance is required based on whether it is ‘more likely than not’ that some portion of the deferred tax assets would not be realized. This evaluation requires significant judgment and changes to our assumptions could result in a material change in the valuation allowance. The ultimate realization of these deferred tax assets is dependent upon the generation of sufficient taxable income during future periods. The Company conducts its evaluation by considering, among other things, all available positive and negative evidence, historical operating results and cumulative earnings analysis, forecasts of future profitability, and the duration of statutory carryforward periods.

There were no income tax payments made for the year ended December 31, 2025.

The Company evaluates its tax position using a two-step process. First, the Company determines whether a tax position is more likely than not (greater than 50 percent probability) to be sustained upon examination, including resolution of any related appeals or litigation processes, based on the technical merits of the position. The Company will then determine the amount of benefit to recognize and record the amount of the benefit that is more likely than not to be realized upon ultimate settlement. The Company has no unrecognized tax benefits as of December 31, 2025.

With certain exceptions, the tax years 2022 and thereafter remain open to examination by the major taxing jurisdictions with which the Company files tax returns.