Income Taxes
We elected to be taxed as a REIT under Sections 856 through 860 of the Internal Revenue Code commencing with our taxable year beginning January 1, 1999. To continue to qualify as a REIT, we must meet a number of organizational and operational requirements, including a requirement that we distribute at least 90% of our annual taxable income to our stockholders, excluding net capital gain. As a REIT, generally we will not be subject to U.S. federal and state corporate income taxes on that portion of our annual taxable income that is distributed to our stockholders. If we fail to qualify for taxation as a REIT in any taxable year, we will be subject to U.S. federal and state corporate income taxes at regular corporate income tax rates and may not be able to qualify as a REIT for four subsequent taxable years. Even if we qualify to be treated as a REIT, we may be subject to certain state, local and foreign taxes on our income and property, and to U.S. federal and state corporate income and excise taxes on our undistributed taxable income.
Effective July 4, 2025, the One Big Beautiful Bill Act was approved, resulting in certain changes to U.S. tax legislation that will impact us and our stockholders. Key provisions include a permanent extension of the 20% deduction for qualified REIT dividends, an increase in the REIT asset test limit for taxable REIT subsidiaries from 20% to 25%, a permanent restoration of 100% bonus depreciation on qualified property acquired after January 19, 2025, and a modification to the base on which the interest deduction limit applies by excluding depreciation, amortization and depletion from adjusted taxable income.
Set forth below is a table that documents our domestic and foreign income tax attributes at December 31, 2025:
TypeJurisdictionAmount (in millions)
Tax Year Expiration
Net operating lossU.S. Federal$489 None
Capital lossU.S. Federal and States2028-2030
Net operating lossU.S. States814 Various
Net operating lossBrazil17 None
Net operating lossCanadaThrough 2042
Capital lossCanadaNone
General business creditU.S. Federal2044
We have recorded a 100% valuation allowance of approximately $5 million against the deferred tax asset related to certain of our foreign net operating loss and capital loss carryovers as of December 31, 2025. We also have recorded a valuation allowance of approximately $5 million against the deferred tax asset related to our accumulated other comprehensive income (“AOCI”) foreign exchange net losses.
The primary components of our net deferred tax assets are as follows (in millions):
 As of December 31,
20252024
Deferred tax assets
Net operating losses, general business credits, and capital loss carryovers$155 $182 
Investments in domestic affiliates— 
Property and equipment
Deferred revenue and expenses27 30 
Foreign exchange net losses (AOCI)12 12 
Total gross deferred tax assets195 227 
Less: Valuation allowance(10)(10)
Total deferred tax assets, net of valuation allowance$185 $217 
Deferred tax liabilities
Total gross deferred tax liabilities— — 
Net deferred tax assets$185 $217 
We believe that it is more likely than not that the results of future operations will generate sufficient taxable income in order to realize our total deferred tax assets, net of a valuation allowance of $10 million, of $185 million.
Our U.S. and foreign income from continuing operations before income taxes were as follows (in millions):
 Year ended December 31,
202520242023
U.S. income$794 $697 $768 
Foreign income24 24 20 
Total$818 $721 $788 

Income tax provision for continuing operations consists of (in millions):
 Year ended December 31,
202520242023
Current—Federal$$— $
—State
—Foreign
14 10 
Deferred—Federal20 15 
—State10 
—Foreign
28 26 
Income tax provision - continuing operations$42 $14 $36 
The differences between the income tax provision calculated at the statutory U.S. federal corporate income tax rate of 21% and the actual income tax provision recorded for continuing operations are as follows (in millions):
 Year ended December 31,
202520242023
Statutory federal income tax provision$172 21 %$151 21 %$165 21 %
Federal income tax adjustments
Non taxable income of Host Inc.(143)(17)%(137)(19)%(144)(18)%
Tax credits— — %(7)(1)%(1)— %
Cross-border tax laws— — %— — %— %
Other(4)— %(3)— %(3)— %
State income tax provision, net 10 %%13 %
Foreign income tax provision%%%
Total$42 %$14 %$36 %
The majority of the effect of the state and local income tax provision consists of Florida, California and Hawaii.
Cash taxes activity, net, included the following (in millions):
 Year ended December 31,
202520242023
U.S. federal$1.1 $0.7 $4.5 
U.S. state and local
California1.6 2.4 — 
Florida0.4 0.4 0.7 
Illinois0.1 0.2 1.4 
Texas0.8 0.7 0.4 
New York0.1 0.1 (1.4)
Massachusetts— 0.5 0.5 
Tennessee0.6 — — 
Philadelphia0.7 0.6 0.4 
Other0.8 0.6 0.9 
5.1 5.5 2.9 
Foreign
Canada4.0 4.2 3.7 
Alberta0.5 0.7 0.4 
Brazil0.7 0.1 0.1 
5.2 5.0 4.2 
Total cash taxes$11.4 $11.2 $11.6 
Our unrecognized tax benefits remained unchanged at $1 million for each of the years ended December 31, 2025 and 2024. All of such uncertain tax position amounts, if recognized, would impact our reconciliation between the income
tax provision calculated at the statutory U.S. federal corporate income tax rate of 21% and the actual income tax provision recorded each year.
As of December 31, 2025, the tax years that remain subject to examination by major tax jurisdictions generally include 2022-2025. There were no material interest or penalties recorded for the years ended December 31, 2025, 2024 and 2023.

Historical Timeline

Fiscal YearFiled
2025Feb 25, 2026Showing above
2024Feb 26, 2025
2023Feb 28, 2024
2022Feb 22, 2023
2021Feb 24, 2022
2020Feb 25, 2021
2019Feb 25, 2020
2018Feb 26, 2019
2017Feb 27, 2018
2016Feb 24, 2017
2015Feb 22, 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.