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Income Taxes
9 Months Ended
Sep. 30, 2022
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
 
We have elected to be taxed as a REIT under the Internal Revenue Code of 1986, as amended, and are generally not subject to federal and state income taxes provided we distribute a sufficient amount of our taxable income to our shareholders and meet other requirements for qualifying as a REIT.  However, we are subject to certain state and local taxes without regard to our REIT status.

On August 31, 2022, the Company completed an internal restructuring intended to comply with Section 351 of the Internal Revenue Code. As a result, the Operating Trust recognized an $82.0 million taxable gain for federal income tax purposes. The resulting gain eliminates in the Company’s condensed consolidated financial statements and has no impact on the Company’s provision for income taxes for the three and nine months ended September 30, 2022.
Our provision for income taxes consists of the following (in thousands):
Three Months Ended September 30,Nine Months Ended September 30,
2022202120222021
Current:
State and local
$(23)$(32)$(81)$(94)
Income tax expense$(23)$(32)$(81)$(94)