Note 10. Income Taxes

The provision for income taxes was as follows for the year ended December 31, 2025:

 

 

Year ended December 31,

 

 

(in thousands)

 

2025

 

 

Current

 

 

 

Federal

 

$

 

 

 

State

 

 

 

 

 

Total current income tax expense

 

$

 

 

 

Deferred

 

 

 

 

 

Federal

 

$

 

17,309

 

 

State

 

 

 

3,200

 

 

Total deferred income tax expense

 

 

 

20,509

 

 

Total income tax expense

 

$

 

20,509

 

 

 

 

 

 

 

 

 

Taxable income generated from certain activities that do not qualify under REIT provisions is earned through the Company's TRSs and is subject to U.S. federal, state, and local income and franchise taxation. The following table reconciles the TRS U.S. federal statutory income tax rate to the TRS effective income tax rate for the year ended December 31, 2025:

 

 

 

 

Year ended December 31,

 

 

 

2025

 

 

(in thousands)

 

 

Amount

 

Percent

U.S. Federal Statutory Tax Rate

 

 

$

 

17,309

 

 

 

21.0

 

%

State and Local Income Taxes, Net of Federal Income Tax Effect (1)

 

 

 

 

3,200

 

 

 

3.8

 

 

Effective Tax Rate

 

 

$

 

20,509

 

 

 

24.8

 

%

 

 

 

 

 

 

 

 

 

 

 

(1)
State taxes in California, Florida and New York made up the majority (greater than 50 percent) of the tax effect in this category.

The following table presents the Company’s income taxes paid (net of refunds) disaggregated by jurisdiction for the year ended December 31, 2025. Income Taxes paid (net of refunds) were not made to any State or foreign jurisdiction and therefore, there are no amounts that are required to be reported by individual jurisdictions.

 

Year ended December 31,

 

(in thousands)

 

2025

 

Federal

 

$

 

8,500

 

State

 

 

 

Foreign

 

 

 

 

Total

 

$

 

8,500

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Deferred income taxes represent the net tax effects of temporary differences between the financial statement carrying amounts of certain assets and liabilities for financial reporting purposes and the amounts used for income tax purposes. The tax effects of significant temporary differences that give rise to net deferred tax liabilities were as follows:

 

 

 

At December 31,

 

(in thousands)

 

2025

 

Deferred tax assets:

 

 

Capitalized interest expense

 

$

 

67,458

 

Capitalized management fee expense

 

 

11,200

 

Net operating loss carryforward

 

 

 

30,624

 

Total deferred tax assets, net of valuation allowance

 

$

 

109,282

 

Deferred tax liabilities:

 

 

 

Land basis adjustments, Spin-Off, and acquired Rausch land assets

 

$

 

56,824

 

Homesite takedown adjustments

 

 

 

13,981

 

Deferred option fee revenue

 

 

 

115,810

 

Total deferred tax liabilities

 

 

 

186,615

 

Deferred tax liabilities, net

 

$

 

77,333

 

As of December 31, 2025, the Company had federal and state net operating loss (“NOL”) carryforwards of approximately $123.1 million that may be carried forward indefinitely and do not expire.

A reduction of the carrying amounts of deferred tax assets by a valuation allowance is required if, based on available evidence, it is more likely than not that such assets will not be realized. The Company evaluated its deferred tax assets as of December 31, 2025 and concluded that it is more likely than not that the deferred tax assets will be realized. This assessment considered all available positive and negative evidence, including recent financial performance, actual earnings, future reversals of existing temporary differences, projected future taxable income, and tax planning strategies. As such, a valuation allowance was not recorded against the deferred tax assets, including the NOL, as of December 31, 2025. The Company had no gross unrecognized tax benefits as of December 31, 2025.

As of December 31, 2024, the Predecessor Millrose Business had federal and state NOL carryforwards of approximately $649.1 million that may be carried forward 10 to 20 years, or indefinitely, depending on the tax jurisdiction.

The need to establish valuation allowances as of December 31, 2024 was assessed by the Predecessor Millrose Business based on the consideration of all available positive and negative evidence using a “more- likely-than-not” standard with respect to whether deferred tax assets will be realized. This assessment considered, among other matters, the nature, frequency and severity of current and cumulative losses, actual earnings, forecasts of future profitability, the duration of statutory carryforward periods, the Predecessor Millrose Business’s experience with loss carryforwards not expiring unused and tax planning alternatives. Based on this assessment, the Predecessor Millrose Business determined that it would not be able to realize its net operating loss carryforwards and recorded a valuation allowance against its deferred tax asset, which also reduced income taxes and effective tax rate to zero as of December 31, 2024. As of December 31, 2024, the Predecessor Millrose Business had no gross unrecognized tax benefits.

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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.