Income Taxes
We conduct our operations as a REIT for U.S. federal income tax purposes. U.S. federal income tax law generally requires that a REIT distribute annually at least 90% of its REIT taxable income, without regard to the deduction for dividends paid and excluding net capital gains, and that it pays taxes at regular corporate income tax rates to the extent that it annually distributes less than 100% of its taxable income. We intend to meet those requirements and as a result, we generally will not be subject to U.S. federal income tax except for the TRS operations.
The operations of VICI Golf (represented by the four golf course businesses), which are held in a TRS and certain of our other subsidiaries that operate in various states and municipalities within North America and the United Kingdom, are subject to various local, state and/or federal income taxes. Accordingly, we provide for a provision for income taxes in relation to these jurisdictions, which includes current and deferred portions. We use the asset and liability method to provide for income taxes, which requires that our income tax expense reflects the expected future tax consequences of temporary differences between the carrying amounts of assets or liabilities for financial reporting versus income tax purposes.
Income before income taxes for the year ended December 31, 2025 of $2,777.9 million was comprised of $2,767.1 million from U.S. operations and $10.8 million from foreign operations.
The composition of our income tax expense (benefit) was as follows:
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| Year Ended December 31, |
| 2025 | | 2024 | | 2023 |
| (In thousands) | Current | | Deferred | | Total | | Current | | Deferred | | Total | | Current | | Deferred | | Total |
| Federal | $ | 2,041 | | | $ | (267) | | | $ | 1,774 | | | $ | 1,808 | | | $ | (702) | | | $ | 1,106 | | | $ | 1,755 | | | $ | 129 | | | $ | 1,884 | |
| State | 378 | | | 15 | | | 393 | | | 1,816 | | | 8 | | | 1,824 | | | 2,481 | | | 13 | | | 2,494 | |
| Foreign | 1,759 | | | (1,491) | | | 268 | | | 641 | | | 6,133 | | | 6,774 | | | 49 | | | (10,568) | | | (10,519) | |
| Income tax expense (benefit) | $ | 4,178 | | | $ | (1,743) | | | $ | 2,435 | | | $ | 4,265 | | | $ | 5,439 | | | $ | 9,704 | | | $ | 4,285 | | | $ | (10,426) | | | $ | (6,141) | |
For the year ended December 31, 2025, income taxes paid, net of refunds received, of $7.3 million were comprised of $3.2 million U.S. Federal income tax, $1.3 million state and local income tax and $2.9 million foreign income tax in Canada.
At December 31, 2025 and 2024, the net effects of temporary differences that gave rise to significant portions of the deferred tax assets and deferred tax liabilities were:
| | | | | | | | | | | |
| (In thousands) | December 31, 2025 | | December 31, 2024 |
| Deferred tax assets: | | | |
| | | |
| CECL allowance - foreign investments | $ | 16,634 | | | $ | 10,584 | |
| Lease liability | 2,126 | | | 2,192 | |
| Accruals, reserves and other | 1,505 | | | 1,256 | |
| | | |
| Total deferred tax assets | 20,265 | | | 14,032 | |
| Deferred tax liabilities: | | | |
| Fixed assets - foreign investments | (9,547) | | | (1,436) | |
| Land, buildings and equipment, net | (5,063) | | | (5,042) | |
| Right of use asset | (2,126) | | | (2,192) | |
| Cumulative translation adjustment | (613) | | | (3,309) | |
| Total deferred tax liabilities | (17,349) | | | (11,979) | |
| Net deferred tax asset | $ | 2,916 | | | $ | 2,053 | |
The following table reconciles our effective income tax rate to the historical U.S. federal statutory rate of 21% for the years ended December 31, 2025, 2024 and 2023:
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| Year Ended December 31, |
| 2025 | | 2024 | | 2023 |
| ($ in thousands) | Amount | | Percent | | Amount | | Percent | | Amount | | Percent |
| Federal income tax expense at statutory rate | $ | 583,363 | | | 21.0 | % | | $ | 564,586 | | | 21.0 | % | | $ | 526,579 | | | 21.0 | % |
| REIT income not subject to U.S. federal income tax | (581,770) | | | (20.9) | | | (563,476) | | | (21.0) | | | (524,791) | | | (20.9) | |
| Pre-tax gain attributable to taxable subsidiaries | 1,593 | | | 0.1 | | | 1,110 | | | — | | | 1,788 | | | 0.1 | |
| State and local income taxes, net of federal benefits | 368 | | | — | | | 1,800 | | | 0.1 | | | 2,474 | | | 0.1 | |
| Foreign income taxes | 269 | | | — | | | 6,774 | | | 0.3 | | | (10,519) | | | (0.4) | |
| Non-deductible expenses and other | 205 | | | — | | | 20 | | | — | | | 116 | | | — | |
| Provision for (benefit from) income taxes | $ | 2,435 | | | 0.1 | % | | $ | 9,704 | | | 0.4 | % | | $ | (6,141) | | | (0.2) | % |
We declared dividends of $1.765, $1.695 and $1.610 per common share during the years ended December 31, 2025, 2024 and 2023, respectively. For U.S. federal income tax purposes, the portion of the dividends allocated to stockholders for the years ended December 31, 2025, 2024 and 2023 are characterized as follows:
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| Year Ended December 31, |
| ($ per share) | 2025 | | 2024 | | 2023 |
| Ordinary dividends | $ | 1.7019 | | | $ | 1.5045 | | | $ | 1.4500 | |
Section 199A dividends (1) | $ | 1.6963 | | | $ | 1.5013 | | | $ | 1.4265 | |
Qualified dividend (1) | $ | 0.0057 | | | $ | 0.0031 | | | $ | 0.0235 | |
| | | | | |
| Non-dividend distribution | $ | 0.0456 | | | $ | 0.1730 | | | $ | 0.0263 | |
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(1)These amounts are a subset of, and are included in, the ordinary dividend amounts.
As of December 31, 2025, we had NOLs of $151.6 million, generated by our REIT, that will expire in 2037, unless they are utilized by us prior to expiration.
As of December 31, 2025, the 2022, 2023, and 2024 tax years remain subject to examination by federal, state and local tax authorities. The tax filings for tax year 2025 have not yet been filed, and once made, will be subject to examination by taxing authorities for a period of three years.