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.
As of December 31, 2025, the Company had $235.9 million of net operating loss carryforwards for federal income tax purposes at the REIT, which may be utilized to offset future taxable income after consideration for the dividends paid deduction. These federal net operating loss carryforwards do not have an expiration date and can be carried forward indefinitely.
The following is a reconciliation of the statutory federal and state rates to the effective rates, for the year ended December 31, 2025:
Year Ended
December 31,
2025
(dollars in thousands)AmountPercent
Computed income tax expense at federal rate
$(8,611)21 %
State taxes, net of federal benefit, if applicable
72 (0.2)%
Nontaxable and nondeductible items
Share-based payment awards
551 (1.3)%
Limitation on executive compensation
446 (1.1)%
Other
(79)0.2 %
Other adjustments
REIT income not subject to corporate income tax
7,770 (19)%
Provision for (benefit from) income taxes/ Effective tax rate
$149 (0.4)%
The following is a reconciliation of the statutory federal and state rates to the effective rates, for the years ended December 31, 2024 and 2023:
Year Ended
December 31,
20242023
(dollars in thousands)AmountPercentAmountPercent
Computed income tax expense at federal rate
$(43,483)21 %$(13,252)21 %
State taxes, net of federal benefit, if applicable
— — %70 — %
Permanent differences in taxable income from GAAP net income
546 — %(261)— %
REIT income not subject to corporate income tax
42,927 (21)%13,538 (21)%
Provision for (benefit from) income taxes/ Effective tax rate
$(10)— %$95 — %
The Company’s permanent differences in taxable income from GAAP net loss attributable to common stockholders in the years ended December 31, 2025, 2024, and 2023, 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.
The amounts of cash income taxes paid by the Company were as follows:
Year Ended
December 31,
(dollars in thousands)2025
Federal
$115 
State and local
New York
51 
New York City
39 
Income taxes paid, net of amounts refunded
$205 
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Historical Timeline

Fiscal YearFiled
2025Mar 2, 2026Showing above
2024Feb 27, 2025
2023Mar 1, 2024
2022Mar 2, 2023
2021Feb 25, 2022
2020Mar 5, 2021
2019Mar 2, 2020
2018Feb 27, 2019
2017Mar 16, 2018

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.