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Income Taxes (Tables)
12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
Schedule of Common Stock Distributions
The following table shows the characterization of the Company’s annual common stock distributions per share:
Year Ended December 31,
202420232022
Ordinary dividends(1)
$0.720440 $0.909692 $0.872948 
Capital gains(2)(3)
0.295060 0.116992 0.183208 
Nondividend distributions0.184500 0.173316 0.143844 
$1.200000 $1.200000 $1.200000 
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(1)For the year ended December 31, 2024, all $0.720440 of ordinary dividends qualified as business income for purposes of Code Section 199A. For the year ended December 31, 2023, the amount includes $0.882312 of ordinary dividends qualified as business income for purposes of Code Section 199A and $0.027380 of qualified dividend income for purposes of Code Section 1(h)(11). For the year ended December 31, 2022, all $0.872948 of ordinary dividends qualified as business income for purposes of Code Section 199A.
(2)For the years ended December 31, 2024, 2023, and 2022, the amount includes $0.215960, $0.036256, and $0.017760, respectively, of unrecaptured Code Section 1250 gain. Pursuant to Treasury Regulation Section 1.1061-6(c), the Company is disclosing additional information related to the capital gain dividends for purposes of Section 1061 of the Code. Code Section 1061 is generally applicable to direct and indirect holders of “applicable partnership interests.” For the years ended December 31, 2024 and 2023, the “One Year Amounts” and “Three Year Amounts” are each zero, since all capital gains relate to Code Section 1231 gains. For the year ended December 31, 2022, the “One Year Amounts” and “Three Year Amounts” are each 89.6708% of the total capital gain distributions and the remaining capital gain distributions are attributable to Code Section 1231 gains, which are not subject to Code Section 1061.
(3)For the years ended December 31, 2024, 2023, and 2022, 100%, 100%, and 10.3292%, respectively, of the capital gain distributions represent gains from dispositions of U.S. real property interests pursuant to Code Section 897 for foreign shareholders.
Schedule of Income Tax Expense (Benefit) From Continuing Operations
The total income tax benefit (expense) from continuing operations consists of the following components (in thousands):
Year Ended December 31,
202420232022
Current
Federal$(2,389)$(1,663)$(632)
State(3,654)(3,325)(689)
Total current$(6,043)$(4,988)$(1,321)
Deferred
Federal$(3,429)$11,682 $3,157 
State5,122 2,923 2,589 
Total deferred$1,693 $14,605 $5,746 
Total income tax benefit (expense) from continuing operations$(4,350)$9,617 $4,425 
Schedule of Reconciliation of Income Tax Expense at Statutory Rates to the Actual Income Tax Expense Recorded
The following table reconciles income tax benefit (expense) from continuing operations at statutory rates to actual income tax benefit (expense) recorded (in thousands):
Year Ended December 31,
202420232022
Tax benefit (expense) at U.S. federal statutory income tax rate on income or loss subject to tax$(11,601)$(1,404)$3,698 
State income tax benefit (expense), net of federal tax (1,389)(1,035)911 
Gross receipts and margin taxes(1,774)(1,647)(956)
Return to provision adjustments(287)(90)1,260 
Change in valuation allowance for deferred tax assets10,698 13,797 194 
Change in tax status of TRS(4)(682)
Total income tax benefit (expense) from continuing operations$(4,350)$9,617 $4,425 
Schedule of Significant Components of the Company's Deferred Tax Asset and Liabilities The following table summarizes the significant components of the Company’s deferred tax assets and liabilities from continuing operations (in thousands):
December 31,
202420232022
Deferred tax assets:
Deferred revenue$103,470 $103,530 $102,504 
Net operating loss carryforward50,041 54,136 62,280 
Expense accruals11,787 12,324 12,399 
Real estate195 850 150 
Other 49 58 689 
Total deferred tax assets165,542 170,898 178,022 
Valuation allowance(2,306)(13,004)(26,098)
Deferred tax assets, net of valuation allowance$163,236 $157,894 $151,924 
Deferred tax liabilities:
Real estate$47,268 $43,488 $52,266 
Other876 818 674 
Deferred tax liabilities$48,144 $44,306 $52,940 
Net deferred tax assets$115,092 $113,588 $98,984 
Schedule of Unrecognized Tax Benefits Roll Forward
The following table summarizes the Company’s unrecognized tax benefits (in thousands):
December 31,
202420232022
Total unrecognized tax benefits at January 1$— $— $469 
Gross amount of decreases for prior years’ tax positions— — (469)
Total unrecognized tax benefits at December 31$— $— $—