Income Taxes
We are organized in conformity with the requirements for qualification and taxation as a REIT under the Internal Revenue Code of 1986, as amended (the “Code”) and, accordingly, we have not provided for U.S. federal income tax on our REIT taxable income that we distribute to our stockholders. We have elected to treat our subsidiaries that participate in certain non-REIT qualifying activities as taxable REIT subsidiaries (“TRSs”). As such, we have provided for their federal, state and foreign income taxes.
Cash paid for income taxes, net of refunds received, was as follows:
Year Ended December 31,
(in millions)202520242023
Federal $0.3 $(0.9)$— 
State and local(a)
1.3 0.8 1.3 
Foreign:
Canada0.1 1.6 5.4 
Withholding taxes0.5 10.0 — 
Cash paid for income taxes, net of refunds received$2.2 $11.5 $6.7 
(a) State and local taxes by jurisdiction:
Texas$0.7 $0.6 $0.6 
Oregon0.2 0.1 0.1 
New York0.1 — 0.1 
New Hampshire0.1 0.1 — 
Massachusetts— 0.1 0.1 
Tennessee— (0.2)0.2 
Other0.2 0.1 0.2 
Total state and local taxes by jurisdiction$1.3 $0.8 $1.3 

The U.S. and foreign components of Income (loss) before provision for income taxes and equity in earnings of investee companies were as follows:
Year Ended December 31,
(in millions)202520242023
United States$146.5 $265.4 $(431.2)
Foreign— 3.7 11.8 
Income (loss) before provision for income taxes and equity in earnings of investee companies$146.5 $269.1 $(419.4)
The following table reconciles Income (loss) before provision for income taxes and equity in earnings of investee companies to REIT taxable income.
Year Ended December 31,
(in millions)202520242023
Income (loss) before provision for income taxes and equity in earnings of investee companies$146.5 $269.1 $(419.4)
Net income (loss) of TRSs(1.2)10.8 151.4 
Income (loss) from REIT operations145.3 279.9 (268.0)
Book/tax differences
Depreciation35.8 24.7 27.9 
Amortization(18.5)(15.8)(13.6)
Dividend from foreign subsidiary— 5.7 2.1 
Stock-based compensation(7.7)9.5 (0.9)
Deferred gain for tax(5.6)(4.2)(6.8)
Investments in joint ventures(2.0)(6.3)5.5 
Gain from sale of Canada— (70.7)— 
Executive compensation13.0 9.2 11.2 
Lease expense5.4 7.9 8.4 
Provision for doubtful accounts4.6 4.1 1.5 
Impairment charges(a)
— 13.1 388.2 
Other16.9 24.0 13.6 
REIT taxable income (estimated)
$187.2 $281.1 $169.1 
(a)Impairment charges related to our Transit business (see Note 4. Long-Lived Assets).

The components of the Provision for income taxes are as follows:
Year Ended December 31,
(in millions)202520242023
Current:
Federal$(0.4)$(0.2)$— 
State and local(0.9)(1.1)(1.0)
Foreign(0.7)(10.9)(3.1)
(2.0)(12.2)(4.1)
Deferred:
Foreign— 1.2 0.1 
— 1.2 0.1 
Provision for income taxes$(2.0)$(11.0)$(4.0)
The difference between income taxes expected at the U.S. federal statutory income tax rate of 21% and the Provision for income taxes is summarized as follows:
Year Ended December 31,
202520242023
(in millions, except percentages)Tax AmountTax RateTax AmountTax RateTax AmountTax Rate
Benefit (provision) for income taxes on income at U.S. statutory rate$(30.8)21.0 %$(56.5)21.0 %$89.2 21.0 %
State and local taxes, net of federal tax benefit(a)
(0.8)0.5 (1.1)0.4 (1.0)(0.2)
Effect of foreign operations:
Canada:
Statutory rate difference between Canada and the U.S. — — 1.1 (0.4)0.6 0.1 
Provincial taxes— — 0.3 (0.1)(1.1)(0.2)
Withholding tax on proceeds of the sale of Canadian operations(0.5)0.3 (10.0)3.7 — — 
Other(0.2)0.1 (1.1)0.4 (0.5)(0.1)
Changes in valuation allowances0.8 (0.5)(5.5)2.0 (4.5)(1.2)
Nontaxable or nondeductible items:
REIT dividends paid deduction30.5 (20.7)58.8 (21.8)24.2 5.7 
Impairment charges(b)
— — — — (110.6)(26.0)
Other nondeductible items(0.9)0.6 2.5 (1.0)(0.6)(0.1)
Other adjustments, net(0.1)0.1 0.5 (0.1)0.3 0.1 
Provision for income taxes$(2.0)1.4 %$(11.0)4.1 %$(4.0)(0.9)%
(a)State and local taxes consist primarily of taxes in Texas and Oregon.
(b)Primarily a permanent book/tax difference for impairment charges related to our Transit business (see Note 4. Long-Lived Assets).

The following table is a summary of the components of deferred income tax assets and liabilities.
As of December 31,
(in millions)20252024
Deferred income tax assets:
Provision for expenses and losses$12.3 $9.9 
Postretirement and other employee benefits2.9 2.7 
Tax credit and loss carryforwards4.0 5.4 
Property, equipment and intangible assets4.9 5.8 
Total deferred income tax assets24.1 23.8 
Valuation allowance(24.1)(23.8)
Deferred income tax assets, net— — 
Deferred income tax liabilities:
Property, equipment and intangible assets— — 
Postretirement and other employee benefits— — 
Other— — 
Total deferred income tax liabilities— — 
Deferred income tax liabilities, net$— $— 
As of December 31, 2025, we had federal, state and local net operating loss carryforwards of $15.1 million. These losses can be carried forward indefinitely for federal tax purposes but are subject to certain federal, state and local utilization limitations.

As of December 31, 2025, there are no undistributed earnings of foreign subsidiaries due to the sale of the Canadian Business in the Transaction in 2024. All undistributed earnings of foreign subsidiaries prior to the Transaction were distributed to our stockholders in 2024.

The reserve for uncertain tax positions of $0.2 million as of December 31, 2025.

We recognize interest and penalty charges related to the reserve for uncertain tax positions as part of income tax expense. These charges were not material for any of the periods presented.
We are subject to taxation in the U.S. and various state, local and foreign jurisdictions. Tax years 2022 to present are open for examination by the tax authorities.

Historical Timeline

Fiscal YearFiled
2025Feb 26, 2026Showing above
2024Feb 28, 2025
2023Feb 22, 2024
2022Feb 23, 2023
2021Feb 24, 2022
2020Feb 26, 2021
2019Feb 26, 2020
2018Feb 27, 2019
2017Feb 28, 2018
2016Feb 23, 2017
2015Feb 29, 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.