Income Taxes
For the year ended December 31, 2025, the Company qualified to be taxed as a REIT under Code Sections 856 through 860. As a REIT, the Company is not subject to U.S. federal income tax to the extent that it makes qualifying distributions of taxable income to its stockholders. To maintain qualification as a REIT, the Company must distribute at least 90% of its annual REIT taxable income (subject to certain adjustments) to its shareholders and meet certain other requirements such as assets it may hold, income it may generate and its shareholder composition. It is generally the Company’s policy to distribute to its shareholders all of the Company’s taxable income.

The state and local tax jurisdictions in which the Company is subject to tax-filing obligations recognize the Company’s status as a REIT and, therefore, the Company generally does not pay income tax in such jurisdictions. The Company may, however, be subject to certain minimum state and local tax filing fees and its TRSs are subject to U.S. federal, state, and local taxes.

The components of income (loss) before income taxes were attributable to the following regions:

December 31, 2025December 31, 2024
(dollars in thousands)
Current Expense (Benefit):
U.S. Federal$1,550 $60 
U.S. State and Local863 (11)
Total Current Income Tax (Benefit) Provision2,413 49 
Deferred Expense (Benefit):
U.S. Federal(3,705)— 
U.S. State and Local3,560 — 
Total Deferred Income Tax (Benefit) Provision(145)— 
Total Expense (Benefit):
U.S. Federal(2,155)60 
U.S. State and Local4,423 (11)
Total Income Tax (Benefit) Provision$2,268 $49 

Income tax expense relates solely to the activities of the Company’s TRSs.

Significant components of the Company’s deferred tax assets and liabilities at December 31, 2025 and December 31, 2024 are as follows:
December 31, 2025December 31, 2024
(dollars in thousands)
Deferred Tax Assets
Reserves$1,546 $— 
Accrued Expenses336 — 
Property and Equipment109 — 
Lease Liability293 — 
Nondeductible Interest Expense4,649 3,604 
Net Operating Losses ("NOLs")97,255 107,089 
State Taxes245 — 
Other135 — 
Deferred Tax Assets, Gross104,568 110,693 
Valuation Allowance(102,182)(110,693)
Total Deferred Tax Assets, Net 2,386  
Deferred Tax Liabilities
Right-Of-Use Asset(293)— 
Intangibles(24,808)— 
Total Deferred Tax Liabilities(25,101) 
Total Deferred Tax Asset (Liability)$(22,715)$ 

A valuation allowance is established when it is more likely than not that some portion or all of the deferred tax assets will not be realized. As of December 31, 2025, the Company has recorded a valuation allowance of $102 million related to certain deferred tax assets of its TRSs. The NOLs and interest disallowed under Code Section 163(j) are subject to an indefinite carryforward period to the extent not utilized.

The following table reconciles the federal statutory income tax rate to the Company’s effective income tax rate for the years ended December 31, 2025 and December 31, 2024:

December 31, 2025December 31, 2024
(dollars in thousands)
AmountPercentAmountPercent
US Federal Statutory Income Tax Rate$48,881 21.00 %$36,984 21.00 %
Domestic Federal Reconciling Items:
Non-Taxable and Nondeductible Items:
  Non-Taxable REIT Income(49,497)(21.27)%(40,571)(23.03)%
       Unrealized Gain/(Losses)2,960 1.27 %— — 
       Transaction Costs2,108 0.91 %— — 
   Changes in Valuation Allowance(7,302)(3.14)%3,435 1.95 %
   Other1,164 0.50 %201 0.11 %
State and Local Taxes, Net of Federal Benefit3,954 1.70 %— — 
Total$2,268 0.97 %$49 0.03 %

The effective tax rate for the year ended December 31, 2025 was 0.97%, compared with 0.03% for the year ended December 31, 2024. The effective tax rate for the years ended December 31, 2025 differed from the U.S. federal statutory rate of 21.0% primarily due to the deduction of dividend distributions under Code Section 857(a) and the change in valuation allowance. The effective tax rates for the year ended December 31, 2024 differed from the U.S. federal statutory rate of 21.0% primarily due to the deduction of dividend distributions under Code Section 857(a) and the change in valuation allowance related to the remeasurement of NOLs and non-deductible interest expense carryforwards.

The Company and its TRSs file income tax returns in the U.S. federal jurisdiction and various state and local jurisdictions. The Company does not expect have any unrecognized tax benefits and does not expect any changes within the next twelve months. The Company’s U.S. federal, state and local tax returns for the tax years ending on or after December 31, 2022, remain open for examination.

Net cash paid (refunds received) for income taxes consisted of the following:
December 31, 2025
(dollars in thousands)
US Federal$2,287 
State and Local Jurisdictions:
California1,000 
Other*243 
Subtotal1,243 
Total$3,530 
*The amount of income taxes paid during the year does not meet the five percent disaggregation threshold.

Historical Timeline

Fiscal YearFiled
2025Feb 18, 2026Showing above
2024Feb 19, 2025
2023Feb 29, 2024
2022Feb 17, 2023
2021Feb 17, 2022
2020Feb 18, 2021
2019Feb 24, 2020
2018Feb 21, 2019
2017Feb 20, 2018
2016Feb 21, 2017
2015Feb 25, 2016

About Income Taxes Disclosures

The income tax disclosure reveals how much a company actually pays in taxes versus what the statutory rate would predict. Analysts focus on the effective tax rate (ETR) reconciliation, which breaks down every item driving the gap between the 21% federal rate and the company's reported ETR — including R&D credits, foreign rate differentials, and state taxes. Deferred tax assets (DTAs) and their valuation allowances signal management's confidence in future profitability: a rising allowance suggests the company doubts it can use accumulated tax benefits. Uncertain tax benefit (UTB) reserves quantify exposure to IRS challenges on aggressive positions.

Key signals to watch: sudden ETR drops without clear operational reasons, large increases in valuation allowances, growing UTB balances, and significant unremitted foreign earnings. Post-TCJA, pay attention to GILTI and BEAT provisions that affect multinational tax structures. Compare the cash taxes paid (from the cash flow statement) against the income tax provision to gauge earnings quality.