Income Taxes
The Company has elected to be taxed as a REIT under the Code. A REIT is generally not subject to U.S. federal, state, and local income tax on the portion of its income that is distributed to its owners if it distributes at least 90% of its REIT taxable income within the prescribed time frames, determined without regard to the deduction for dividends paid and excluding any net capital gains. The Company intends to operate in a manner which will allow it to continue to meet the requirements for qualification as a REIT. Accordingly, Ellington Financial Inc. does not believe that it will be subject to U.S. federal, state, and local income tax on the portion of its net taxable income that is distributed to its stockholders as long as certain asset, income, and share ownership tests are met.
Cash dividends declared by the Company that do not exceed its current or accumulated earnings and profits will be considered ordinary income to stockholders for income tax purposes unless all or a portion of a dividend is designated by the Company as a capital gain dividend. Distributions in excess of the Company's current and accumulated earnings and profits will be characterized as return of capital or will be treated by shareholders as capital gains.
The following table details the tax characteristics of the Company's dividends declared on its shares of common and preferred stock for the years ended December 31, 2024, 2023, and 2022.
Year Ended December 31,
Tax Characteristic202420232022
Ordinary income84.1 %71.3 %69.0 %
Return of capital14.8 %28.2 %30.4 %
Capital gains1.1 %0.5 %0.6 %
100.0 %100.0 %100.0 %
Certain foreign and domestic subsidiaries of the Company have elected to be treated as TRSs and therefore are taxed as corporations for U.S. federal, state, and local income tax purposes. To the extent that those entities incur, or are expected to incur, U.S. federal, state, or local income taxes, or foreign income taxes, such tax expense is recognized by the Company.
The Company accounts for income taxes in accordance with ASC 740, Income Taxes, or "ASC 740." Deferred income taxes reflect the net tax effects of temporary differences that may exist between the carrying amounts of assets and liabilities under U.S. GAAP and the carrying amounts used for income tax purposes. For the years ended December 31, 2024, 2023, and 2022, the Company recorded income tax expense (benefit) of $0.6 million, $0.5 million, and $(17.7) million, respectively. The Company evaluates its deferred tax assets for recoverability using a consistent approach which considers the relative impact of negative and positive evidence, including historical profitability and projections of future taxable income. Based upon the available evidence at December 31, 2024, the Company determined that it was more likely than not that the deferred tax assets of its TRS would not be utilized in future periods; a valuation allowance of $71.3 million was recorded to fully reserve against these deferred tax assets.
The following table summarizes the Company's (benefit) provision for income tax for the years ended December 31, 2024, 2023, and 2022.
As of December 31,
(In thousands)202420232022
Current provision for income tax
Federal$(167)$— $— 
State779 457 — 
Total current provision for income tax, net612 457 — 
Deferred (benefit) provision for income tax (1)
Federal— — (13,229)
State— — (4,487)
Total deferred (benefit) provision for income tax, net— — (17,716)
Total (benefit) provision for income tax$612 $457 $(17,716)
(1)Includes income tax expense (benefit) of $(2.9) million from a bargain purchase gain for the year ended December 31, 2022.
The following table details the components of the Company's net deferred tax asset (liability) at December 31, 2024 and 2023.
As of December 31,
(In thousands)20242023
Deferred tax asset
Net operating loss available for carry-back and carry-forward(1)(2)
$92,543 $84,185 
Net capital loss carry-forward(2)
10,511 12,746 
Basis difference for investments(31,730)(13,001)
Valuation allowance(71,324)(83,930)
Deferred tax asset— — 
Deferred tax liability
Basis difference for investments— — 
Valuation allowance— — 
Deferred tax liability— — 
Net deferred tax asset (liability), net of valuation allowance$— $— 
(1)Includes state net operating losses available for carry-back and carry-forward as of December 31, 2024 and 2023 of $29.5 million and $20.8 million, respectively. These deferred tax assets were fully offset by a valuation allowance.
(2)Includes deferred tax assets for net operating losses of $45.1 million and net capital loss carry-forwards of $35.9 million related to the Arlington Merger. Of the deferred tax assets relating to net capital loss carry-forwards acquired, $28.0 million expired as of December 31, 2023.
The net operating loss and net capital loss carry-forward balances as of December 31, 2024 and 2023, shown in the table above, are related to pretax U.S. federal and state net operating loss of $329.9 million and $322.5 million, respectively, for December 31, 2024 and 2023, and pretax U.S. federal and state net capital loss carry-forwards of $37.5 million and $48.8 million, respectively, for December 31, 2024 and 2023. If not utilized, certain U.S. federal and state net operating loss and net capital loss carry-forwards will expire between 2026 and 2028, whereas others have an unlimited carryforward period.
The following table details the reconciliation between the Company's U.S. federal and state statutory income tax rate and the effective tax rate for the years ended December 31, 2024, 2023, and 2022.
Year Ended December 31,
202420232022
Federal statutory rate21.00 %21.00 %21.00 %
State statutory rate, net of federal benefit0.53 %0.54 %4.41 %
Income attributable to non-controlling interests(0.16)%(0.76)%0.07 %
REIT earnings not subject to corporate taxes(18.30)%(29.58)%2.72 %
Deferred tax loss— %— %3.22 %
Bargain purchase gain— %— %2.37 %
Change in valuation allowance(8.54)%9.34 %(13.85)%
Prior period adjustment5.88 %— %— %
Effective tax rate0.41 %0.54 %19.94 %
Based on its analysis of any potential uncertain income tax positions, the Company concluded it did not have any uncertain tax positions that meet the recognition or measurement criteria of ASC 740 as of December 31, 2024 or 2023. Tax authorities in the relevant jurisdictions may select the Company's tax returns for audit and propose adjustments before the expiration of the statute of limitations. Tax returns filed for the Company's open tax years or any ongoing audits remain open to adjustment in the major tax jurisdictions.
Free Sentinel

Want the next Ellington Financial Inc. income taxes disclosure the moment it drops?

Set a Sentinel and we'll alert you the moment Ellington Financial Inc.'s next filing hits EDGAR. No credit card, your email never gets sold.

Track for free

Historical Timeline

Fiscal YearFiled
2024Mar 3, 2025Showing above
2020Mar 16, 2021
2019Mar 13, 2020

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.