Note 23—Income Taxes

The Company’s effective tax rate was (36.3)% for the year ended December 31, 2025 and (12.9)% for the year ended December 31, 2024. The Company’s TRS recognized a tax benefit of $34.6 million on a pretax loss of $197.1 million while the Company’s consolidated pretax income was $93.8 million for the year ended December 31, 2025. For 2024, the TRS recognized a tax benefit of $18.6 million on pretax loss of $57.9 million while the Company’s reported consolidated pretax income was $142.6 million. The primary difference between the Company’s effective tax rate and the statutory tax rate is generally attributable to nontaxable REIT income resulting from the dividends paid deduction.

The Company assesses the available positive and negative evidence to estimate whether sufficient future taxable income will be generated to permit use of the existing deferred tax assets. On the basis of this evaluation, as of December 31, 2025, the valuation allowance remains zero. The TRS has a significant net deferred tax liability position, which indicates the TRS will utilize all of its deferred tax assets. The amount of deferred tax assets considered realizable could be adjusted in future periods based on future income.

In general, cash dividends declared by the Company will be considered ordinary income to the shareholders for income tax purposes. Some portion of the dividends may be characterized as capital gain distributions or a return of capital. Subject to certain limitations, domestic non-corporate shareholders may be allowed a 20% deduction from taxable income for ordinary REIT dividends.

The following table summarizes the approximate tax characterization of distributions to shareholders for 2025, 2024 and 2023. Distributions included in the table below are based on the tax year to which the distribution is attributed to shareholders in accordance with rules promulgated under the Internal Revenue Code:

 

Year ended December 31,

 

Ordinary
income

 

 

Qualified dividend income

 

 

Long term
capital gain

 

 

Return of
capital

 

 

Sec. 199A dividend

 

Common Shares

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2025

 

 

100

%

 

 

%

 

 

%

 

 

%

 

 

100

%

2024

 

 

100

%

 

 

27

%

 

 

%

 

 

%

 

 

73

%

2023

 

 

19

%

 

 

19

%

 

 

%

 

 

81

%

 

 

%

Preferred Shares (Classes A, B and C)

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2025

 

 

100

%

 

 

%

 

 

%

 

 

%

 

 

100

%

2024

 

 

100

%

 

 

27

%

 

 

%

 

 

%

 

 

73

%

2023

 

 

100

%

 

 

100

%

 

 

%

 

 

%

 

 

%

The Company has elected to treat its subsidiary, PMC, as a TRS. Income from a TRS is only included as a component of REIT taxable income to the extent that the TRS makes dividend distributions of income to the Company. The TRS did not make any dividend distributions to the Company in 2025. A TRS is subject to corporate federal and state income tax. Accordingly, a provision for income taxes for PMC is included in the consolidated statements of operations.

The following table details the Company’s (benefit from) provision for income taxes which relates primarily to the TRS for the years presented:

 

 

 

Year ended December 31,

 

 

 

2025

 

 

2024

 

 

2023

 

 

 

(in thousands)

 

Current expense:

 

 

 

 

 

 

 

 

 

Federal

 

$

 

 

$

1,051

 

 

$

6

 

State

 

 

5,204

 

 

 

 

 

 

 

   Total current expense

 

 

5,204

 

 

 

1,051

 

 

 

6

 

Deferred (benefit) expense:

 

 

 

 

 

 

 

 

 

Federal

 

 

(42,828

)

 

 

(16,898

)

 

 

32,391

 

State

 

 

3,570

 

 

 

(2,489

)

 

 

12,344

 

Total deferred (benefit) expense

 

 

(39,258

)

 

 

(19,387

)

 

 

44,735

 

Total (benefit from) provision for income taxes

 

$

(34,054

)

 

$

(18,336

)

 

$

44,741

 

The following table is a reconciliation of the Company’s provision for income taxes at statutory rates to the provision for income taxes at the Company’s effective income tax rate:

 

 

 

Year ended December 31,

 

 

 

2025

 

 

2024

 

 

2023

 

 

 

Amount

 

 

Rate

 

 

Amount

 

 

Rate

 

 

Amount

 

 

Rate

 

 

 

(dollars in thousands)

 

Federal income tax expense at statutory tax rate

 

$

19,702

 

 

 

21.0

%

 

$

29,956

 

 

 

21.0

%

 

$

51,323

 

 

 

21.0

%

State and local income taxes, net of federal
   income tax effect (1)

 

 

7,163

 

 

 

7.6

%

 

 

(6,169

)

 

 

(4.3

)%

 

 

9,341

 

 

 

3.8

%

Nontaxable or Nondeductible Items:

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Effect of non-taxable REIT (income) loss

 

 

(61,098

)

 

 

(65.1

)%

 

 

(42,110

)

 

 

(29.5

)%

 

 

(18,778

)

 

 

(7.7

)%

Convertible debt adjustment

 

 

411

 

 

 

0.4

%

 

 

186

 

 

 

0.1

%

 

 

2,444

 

 

 

1.0

%

Other

 

 

(232

)

 

 

(0.2

)%

 

 

(199

)

 

 

(0.2

)%

 

 

411

 

 

 

0.2

%

Effective income tax rate

 

$

(34,054

)

 

 

(36.3

)%

 

$

(18,336

)

 

 

(12.9

)%

 

$

44,741

 

 

 

18.3

%

 

(1)
The States that contribute to the majority (greater than 50%) of the tax effect in this category include California, Florida, New York and New Jersey for 2025 and 2023 and California, Florida, Maryland, New York, New Jersey and Pennsylvania for 2024.

 

 

The Company’s components of the (benefit from) provision for deferred income taxes are as follows:

 

 

Year ended December 31,

 

 

2025

 

 

2024

 

 

2023

 

 

(in thousands)

 

Net operating loss carryforward

$

(33,044

)

 

$

16,801

 

 

$

3,199

 

Mortgage servicing rights

 

(12,832

)

 

 

(42,893

)

 

 

22,924

 

Excess interest expense disallowance

 

9,010

 

 

 

2,675

 

 

 

15,114

 

Liability for losses under representations and warranties

 

331

 

 

 

4,760

 

 

 

3,108

 

Real estate valuation loss

 

52

 

 

 

(31

)

 

 

107

 

Other

 

(2,775

)

 

 

(699

)

 

 

283

 

Total (benefit from) provision for deferred income taxes

$

(39,258

)

 

$

(19,387

)

 

$

44,735

 

 

 

Income taxes paid are summarized below:

 

 

 

Year ended December 31,

 

 

 

2025

 

 

2024

 

 

2023

 

 

 

(in thousands)

 

US Federal

 

$

 

 

$

3,900

 

 

$

3,900

 

US State and Local:

 

 

 

 

 

 

 

 

 

Maryland

 

 

715

 

 

 

837

 

 

 

1,352

 

California

 

 

660

 

 

 

1,298

 

 

 

50

 

Alabama

 

 

335

 

 

 

243

 

 

 

267

 

New York

 

 

224

 

 

 

548

 

 

 

266

 

Oregon

 

 

171

 

 

 

172

 

 

 

96

 

Other

 

 

226

 

 

 

808

 

 

 

586

 

 

 

 

2,331

 

 

 

3,906

 

 

 

2,617

 

Total income taxes paid

 

$

2,331

 

 

$

7,806

 

 

$

6,517

 

 

The components of income taxes payable are as follows:

 

 

December 31, 2025

 

 

December 31, 2024

 

(in thousands)

 

Taxes currently receivable

$

(12,211

)

 

$

(15,085

)

Deferred income taxes payable

 

139,687

 

 

 

178,946

 

Income taxes payable

$

127,476

 

 

$

163,861

 

 

 

The tax effects of temporary differences that gave rise to deferred income tax assets and liabilities are presented below:

 

 

December 31, 2025

 

 

December 31, 2024

 

(in thousands)

 

Deferred income tax assets:

 

 

 

 

 

Net operating loss carryforward

$

134,897

 

 

$

101,853

 

Excess interest expense disallowance

 

30,819

 

 

 

39,829

 

Liability for losses under representations and warranties

 

1,353

 

 

 

1,684

 

REO valuation loss

 

50

 

 

 

102

 

Other

 

2,385

 

 

 

598

 

Gross deferred tax assets

 

169,504

 

 

 

144,066

 

Valuation allowance

 

 

 

 

 

Deferred tax assets after valuation allowance

 

169,504

 

 

 

144,066

 

Deferred income tax liabilities:

 

 

 

 

 

Mortgage servicing rights

 

309,191

 

 

 

322,023

 

Other

 

 

 

 

989

 

Gross deferred tax liabilities

 

309,191

 

 

 

323,012

 

Net deferred income tax liability

$

139,687

 

 

$

178,946

 

The net deferred income tax liability is recorded in Income taxes payable in the consolidated balance sheets.

The Company has net operating loss carryforwards of $511.2 million and $384.3 million at December 31, 2025 and December 31, 2024, respectively. Losses that occurred prior to 2018 expire between 2033 and 2036. Net operating losses arising in tax years beginning after December 31, 2017 can be carried forward indefinitely but their use is limited to 80% of taxable income for tax years beginning after December 31, 2020.

We evaluated the deferred tax assets of our TRS and determined a deferred tax valuation allowance is not required based on sufficient TRS GAAP income. In our evaluation, we consider, among other things, taxable loss carryback availability, expectations of sufficient future taxable income, trends in earnings, existence of taxable income in recent years, the future reversal of temporary differences, and available tax planning strategies that could be implemented, if required. We establish valuation allowances based on the consideration of all available evidence using a more-likely-than-not standard.

At December 31, 2025 and December 31, 2024, the Company had no unrecognized tax benefits and does not anticipate any increase in unrecognized tax benefits. Should the accrual of any interest or penalties relative to unrecognized tax benefits be necessary, it is the Company’s policy to record such accruals in the Company’s income tax accounts. No such accruals existed at December 31, 2025 and December 31, 2024.

The Company files U.S. federal and state income tax returns for both the REIT and the TRS. These federal income tax returns for 2022 and forward are subject to examination. The Company’s state income tax returns are generally subject to examination for 2021 and forward.

Historical Timeline

Fiscal YearFiled
2025Feb 18, 2026Showing above
2020Feb 26, 2021

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.