Income Taxes
We have been organized and operated, and we expect to continue to be organized and operate in a manner to qualify as a REIT. To qualify as a REIT, we must satisfy requirements related to, among other things, the real estate qualification of sources of our income, the real estate composition and values of our assets, the amounts we distribute to our stockholders annually and the diversity of ownership of our stock. To the extent we continue to remain qualified as a REIT, we generally will not be subject to U.S. federal (and state) income tax on taxable income generated by our REIT activities that we distribute annually to our stockholders. Accordingly, no provision for U.S. federal income taxes has been included in our accompanying consolidated financial statements for the years ended December 31, 2025, 2024 and 2023 related to our REIT activities other than taxes related to our sale of built-in gain property. Our TRSs are generally subject to U.S. federal, state and local, and foreign income taxes (as applicable).
The components of our provision (benefit) for income taxes were:
Year Ended December 31,
202520242023
(in millions)
Current:
U.S. Federal$$$
State— (4)19 
Total current24 
Deferred:
U.S. Federal(43)
State(19)10 
Total deferred(62)14 
Total provision (benefit) for income taxes:
U.S. Federal(38)
State(23)29 
Total provision (benefit) for income taxes$$(61)$38 

Reconciliations of our tax provision at the U.S. statutory rate to the provision (benefit) for income taxes were:
 Year Ended December 31,
 202520242023
AmountPercentAmountPercentAmountPercent
 
(dollars in millions)
Statutory U.S. federal income tax (benefit) provision$(56)21 %$35 21 %$30 21 %
State income taxes, net of U.S. federal tax benefit— — (6)(3)29 19 
Change in deferred tax asset valuation allowance— — (54)(33)— — 
REIT income not subject to tax60 (23)(24)(15)(23)(16)
Derecognition and remeasurement of deferred taxes— — (14)(9)— — 
Other(1)
Provision (benefit) for income taxes$(3)%$(61)(37)%$38 26 %

Deferred income taxes represent the tax effect of the differences between the book and tax bases of assets and liabilities plus carryforward items. The composition of net deferred tax balances were as follows:
 December 31,
 20252024
 
(in millions)
Deferred income tax assets(1)
$36 $39 
Deferred income tax liabilities(2)
(1)— 
Net deferred tax asset$35 $39 
____________________________________________________________________________________
(1)Included within other assets in our consolidated balance sheets, net of valuation allowance.
(2)Included within other liabilities in our consolidated balance sheets.
The tax effects of the temporary differences and carryforwards that give rise to our net deferred tax balances were:
 December 31,
 20252024
 
(in millions)
Deferred tax assets:
Net operating loss carryforwards$44 $45 
Investments
Interest expense limitation
Other
Total gross deferred tax assets58 58 
Less: valuation allowance(5)(5)
Deferred tax assets53 53 
Deferred tax liabilities:
Investments(15)(13)
Other(3)(1)
Deferred tax liabilities(18)(14)
Net deferred tax asset$35 $39 
As of December 31, 2025, we had U.S. federal and state net operating loss carryforwards of approximately $698 million, which resulted in deferred tax assets of $44 million. Our U.S. federal net operating loss carryforwards of approximately $259 million are not subject to expiration.
We have U.S. state net operating loss carryforwards of approximately $439 million, certain of which will begin to expire in 2031.
Income taxes paid net of refunds received during the year ended December 31, 2025 were as follows:
Year Ended December 31,
2025
(in millions)
U.S. Federal$
State and local
Total income taxes paid$
We paid $15 million and $7 million in income taxes during the years ended December 31, 2024, and 2023, respectively.
The cash distributions to stockholders in 2025, 2024 and 2023 are characterized, for U.S. federal income tax purposes, as follows:
Year Ended December 31,
202520242023
Common distributions (per share):
Ordinary dividends(1)
$0.759540 $1.285731 $0.000000 
Capital gain distributions(2)
0.240460 0.114269 2.150000 
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(1)For the years ended December 31, 2025 and 2024, the ordinary dividends include qualified dividends of $0.025164 and $0.292918, respectively.
(2)Capital gain distribution disclosure pursuant to Treasury Regulation §1.1061-6(c). The following additional information relates to the capital gain distributions for calendar years 2025, 2024 and 2023, as reported on Park Hotels & Resorts Inc. Form 1099-DIV, Box 2a. For purposes of Internal Revenue Code Section 1061, which is generally applicable to direct and indirect holders of “applicable partnership interests”: (i) the “One Year Amounts” are $0.000000 per share, and (ii) the “Three Year Amounts” are $0.000000 per share, with respect to the 2025, 2024 and 2023 capital gain distributions.

Historical Timeline

Fiscal YearFiled
2025Feb 20, 2026Showing above
2024Feb 20, 2025
2023Feb 28, 2024
2022Feb 23, 2023
2021Feb 18, 2022
2020Feb 26, 2021
2019Feb 27, 2020
2018Feb 28, 2019
2017Mar 1, 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.