Ryman Hospitality Properties, Inc. Income Taxes Disclosure

10. Income Taxes

The Company has elected to be taxed as a REIT effective January 1, 2013, pursuant to the U.S. Internal Revenue Code of 1986, as amended. As a REIT, the Company generally will not be subject to federal corporate income taxes on

ordinary taxable income and capital gains income from real estate investments that it distributes to its stockholders. The Company pays federal and state corporate income taxes on earnings of its taxable REIT subsidiaries (“TRSs”).

The income tax (provision) benefit for continuing operations consists of the following (amounts in thousands):

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The Company evaluates its deferred tax assets each reporting period to determine if it is more likely than not that those assets will be realized or if a valuation allowance is needed. In the fourth quarter of 2023, due to continued improvement in the Company’s financial results coming out of the COVID-19 pandemic and the projected future taxable income of its TRSs, the Company determined that the release of a significant portion of its federal and state valuation allowance was appropriate. This release of valuation allowance of $112.5 million was the primary factor in the income tax benefit for 2023.

The Company is required to distribute at least 90% of its annual taxable income, excluding net capital gains, to its stockholders in order to maintain its qualification as a REIT. The taxability of distributions to stockholders is determined by the Company’s earnings and profits, which differs from net income reported for financial reporting purposes. The estimated taxability of cash distributions paid to common stockholders is shown in the table below (per common share):

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The differences between the income tax provision calculated at the statutory U.S. federal income tax rate of 21% and the actual income tax (provision) benefit recorded for continuing operations are as follows (amounts in thousands):

Income taxes paid (net of refunds received) consist of the following (in thousands):

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Significant components of the Company’s deferred tax assets and liabilities at December 31 are as follows (amounts in thousands):

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TRS federal net operating loss carryforwards at December 31, 2025 totaled $533.5 million, resulting in a deferred tax asset of $112.0 million, and do not expire. The REIT has no federal net operating losses as of December 31, 2025. The TRS federal interest limitation carryforward at December 31, 2025 totaled $71.4 million, resulting in a deferred tax asset of $15.0 million that does not expire. The Company has assessed the need for a valuation allowance and determined that it is more likely than not that its deferred tax assets will be realized; therefore, no valuation allowance has been recorded for federal purposes.

State net operating loss carryforwards at December 31, 2025 totaled $608.7 million, resulting in a deferred tax benefit of $25.0 million, which will expire between 2026 and 2045. The use of certain state net operating losses, credits and other state deferred tax assets is subject to limitations based on the future taxable earnings of separate legal entities. As a result, a valuation allowance has been provided for certain state deferred tax assets, including loss carryforwards. The valuation allowance related to state deferred tax assets decreased $0, $0 and $(25.1) million in 2025, 2024 and 2023, respectively.

The Company has concluded IRS examinations of the TRS through the 2015 tax year. For federal income tax purposes and substantially all the states with which the Company has nexus, the statute of limitations has expired through 2021. However, the Company has federal and state net operating loss carryforwards from closed years, which could be adjusted upon audit. The Company is routinely subject to other various jurisdictional income tax audits; however, there were no outstanding state or local audits at December 31, 2025.

At December 31, 2025 and 2024, the Company had no accruals for unrecognized tax benefits. The Company recognizes interest and penalties related to uncertain tax positions, if any, in income tax expense. At December 31, 2025 and 2024, the Company has accrued no interest or penalties related to uncertain tax positions.