Income Taxes
The Company’s taxable income before dividend distributions differs from its pre-tax net income for GAAP purposes primarily due to differences in timing between GAAP and tax accounting related to restructuring charges, provision for credit losses and amendments to loans treated as “significant modifications” for tax under applicable Treasury regulations. These book to tax differences in the REIT are not reflected in the consolidated financial statements as the Company assumes it will retain its REIT status.
The following is a reconciliation of the statutory federal and state rates to the effective rates, for the years ended December 31, 2024, 2023, and 2022:
Year Ended
December 31,
202420232022
(dollars in thousands)AmountPercentAmountPercentAmountPercent
Computed income tax expense at federal rate
$(43,483)21 %$(13,252)21 %$(8,570)21 %
State taxes, net of federal benefit, if applicable
— — %70 — %14 — %
Permanent differences in taxable income from GAAP net income
546 — %(261)— %(228)%
REIT income not subject to corporate income tax
42,927 (21)%13,538 (21)%8,801 (22)%
Provision for (benefit from) income taxes/ Effective Tax Rate
$(10)— %$95 — %$17 — %
The Company’s permanent differences in taxable income from GAAP net loss attributable to common stockholders in the years ended December 31, 2024, 2023, and 2022, were primarily due to recurring differences in compensation expense.
Based on the Company’s evaluation, it has been concluded that there are no significant uncertain tax positions requiring recognition in the Company’s consolidated financial statements of a contingent tax liability for uncertain tax positions. Additionally, there were no amounts accrued for penalties or interest as of, or during, the periods presented in these
consolidated financial statements.

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.