Subsequent to the Spin-Off the Company intends to elect to be taxed as a REIT with the filing of its U.S. federal income tax return for the year ended December 31, 2018. To the extent we qualify as a REIT, we generally will not be subject to U.S. federal income tax on taxable income generated by our REIT activities that we distribute to our stockholders; however, our TRS is subject to U.S. federal, state and local income taxes and our REIT may be subject to state and local taxes. Tax benefit related to discontinued operations in the amount of $1 million is recorded in “loss from discontinued operations, net of tax” in our statement of operations.

From January 1, 2018 to the Spin-Off Date, all of the taxable income from operations (both continuing and discontinued operations) and the tax gain from the Spin-Off will be included in the U.S. federal and state income tax returns of LQH and Wyndham will be responsible for their payment. However, in accordance with GAAP, the tax expense for the three months ended March 31, 2018 associated with our continuing operations is included in our current tax expense.

The following table presents the Company’s income tax (expense) benefit for the three months ended March 31, 2019 and 2018 (in millions):

	Three Months Ended March 31,
	2019			2018
Current tax expense	$	(5	)	$	(1	)
Deferred tax benefit		—			2
Total income tax (expense) benefit	$	(5	)	$	1

The provision for the three month period ended March 31, 2019 differs from the statutory federal tax rate of 21%, primarily due to the impact of the REIT election and state income taxes. The provision for the three month period ended March 31, 2018 differs from the statutory federal tax rate of 21% primarily due to the impact of certain restructuring costs and state income taxes.