Income Taxes

Income (loss) before income taxes by geographic area is as follows:



	Years Ended December 31,
	2011		2010			2009
Domestic	$	168,804	$	(342,333	)	$	(193,055	)
Foreign (a)	11,003		4,228			2,532
	$	179,807	$	(338,105	)	$	(190,523	)

____________________


(a)	Inclusive of income (loss) before income taxes from Australia and Puerto Rico.

The benefit (provision) for income taxes consists of the following:



	Years Ended December 31,
	2011			2010			2009
Current:
Federal	$	3,213		$	4,038		$	5,803
Foreign	(3,377		)	(2,187		)	(1,904		)
State	(3,557		)	(1,201		)	(1,909		)
Total current	(3,721		)	650			1,990
Deferred:
Federal	1,054			30,770			56,152
Foreign	(694		)	(298		)	—
State	(4,986		)	(4,276		)	18,258
Total deferred	(4,626		)	26,196			74,410
Total tax benefit (provision)	$	(8,347	)	$	26,846		$	76,400

For the year ended December 31, 2010, the Company received a $9.6 million alternative minimum tax carryback refund, of which $5.6 million was recorded in 2009, and $4.0 million reduced its alternative minimum tax credit carryforward. The alternative minimum tax credit has an indefinite carryforward period.

A reconciliation between the benefit (provision) for income taxes and the amount computed by applying the federal statutory income tax rate to the loss before income taxes is as follows:



	Years Ended December 31,
	2011			2010			2009
Benefit (provision) for income taxes at statutory rate	$	(62,932	)	$	118,337		$	66,683
Tax effect of foreign income (losses)	3,851			1,480			886
Expenses for which no federal tax benefit was recognized	(5,433		)	(3,657		)	(803		)
Valuation allowances	61,921			(85,605		)	—
State tax (provision) benefit, net of federal	(4,565		)	(3,560		)	10,627
Foreign tax	(4,071		)	(2,485		)	(1,904		)
Change in unrecognized tax benefits	1,693			—			—
Other	1,189			2,336			911
	$	(8,347	)	$	26,846		$	76,400

The components of the net deferred income tax assets and liabilities are as follows:



	December 31,
	2011			2010
Deferred income tax liabilities:
Property and equipment	$	511,205		$	486,577
Deferred site rental receivable	238,203			164,867
Intangible assets	655,512			689,597
Total deferred income tax liabilities	1,404,920			1,341,041
Deferred income tax assets:
Net operating loss carryforwards	908,747			926,444
Deferred ground lease payable	109,948			104,324
Alternate minimum tax credit carryforward	3,591			3,591
Accrued liabilities	81,719			78,752
Receivables allowance	2,253			2,175
Prepaid lease	405,993			430,558
Derivative instruments	74,214			75,960
Available-for-sale securities	29,402			25,289
Other	5,293			4,415
Valuation allowances	(228,417		)	(318,055		)
Total deferred income tax assets, net	1,392,743			1,333,453
Net deferred income tax asset (liabilities)	$	(12,177	)	$	(7,588	)

Before giving effect to any valuation allowances, the Company is in an overall net deferred tax asset position. Due to the Company's history of operating losses, it has recorded a valuation allowance on its net deferred tax assets that do not meet the "more likely than not" realization threshold. As a result, during 2011 the Company was limited in its ability to recognize tax benefits in its results of operations. During 2010, the Company continued to incur taxable losses for which recognition of the federal tax benefits were unable to be recorded, except for $19.8 million of federal tax benefit recorded predominately as a result of discrete events, including the acquisition of NewPath (see note 3). If the NextG Networks, Inc. ("NextG") acquisition is consummated, the Company expects to record a federal deferred tax liability in connection with the purchase accounting. In that event, the Company would expect to reverse its federal valuation allowance, except for the portion related to equity investments, as an income tax benefit in the quarter that the NextG acquisition closes. If the Company continues to record income before income taxes, as it has for each quarter since the fourth quarter of 2010, the Company would expect to reverse a portion of its federal valuation allowance during late 2012, if not previously reversed as a result of the NextG acquisition.

The components of the net deferred income tax assets (liabilities) are as follows:



	December 31, 2011								December 31, 2010
Classification	Gross		Valuation Allowance			Net			Gross		Valuation Allowance			Net
Federal	$	33,103	$	(55,980	)	$	(22,877	)	$	93,970	$	(117,901	)	$	(23,931	)
State	45,813		(34,156		)	11,657			51,799		(35,155		)	16,644
Foreign	63,110		(64,067		)	(957		)	68,365		(68,666		)	(301		)
Other comprehensive income (loss)	74,214		(74,214		)	—			96,333		(96,333		)	—
Total	$	216,240	$	(228,417	)	$	(12,177	)	$	310,467	$	(318,055	)	$	(7,588	)

The valuation allowance recorded in other comprehensive income relates to the changes in the Company's overall deferred tax position due to the deferred tax asset recorded in conjunction with the decline in the fair market value of the Company's interest rate swaps and change in unrealized gain (loss) on available-for-sale securities. The Company's deferred tax assets as of December 31, 2011 and 2010 in the table above do not include $55.3 million and $42.7 million, respectively, of excess tax benefits relating to stock-based compensation that are a component of net operating losses. Total stockholders' equity as of December 31, 2011 will be increased by $55.3 million if and when any such excess tax benefits are ultimately realized.

At December 31, 2011, the Company had U.S. federal and state net operating loss carryforwards of approximately$2.5 billion and $1.1 billion, respectively, which are available to offset future taxable income. These amounts include $0.1 billion of losses related to stock-based compensation. The Company also had foreign net operating loss carryforwards of $0.1 billion. If not utilized, the Company's U.S. federal net operating loss carryforwards expire starting in 2021 and ending in 2030, and the state net operating carryforwards expire starting in 2012 and ending in 2031. The foreign net operating loss carryforwards predominately remain available indefinitely provided certain continuity of business requirements is met. The utilization of the loss carryforwards is subject to certain limitations. The Company's U.S. federal and state income tax returns generally remain open to examination by taxing authorities until three years after the applicable loss carryforwards have been used or expired.

As of December 31, 2011, the total amount of unrecognized tax benefits that would impact the effective tax rate, if recognized, was $8.4 million. The aggregate changes in the balance of unrecognized tax benefits are as follows:



	Years Ended December 31,
	2011			2010
Balance at beginning of year	$	9,255		$	3,213
Additions based on current year tax positions	2,334			6,042
Reductions as a result of the lapse of statute limitations	(3,213		)	—
Balance at end of year	$	8,376		$	9,255

From time to time, the Company is subject to examinations by various tax authorities in jurisdictions in which the Company has business operations. The Company regularly assesses the likelihood of additional assessments in each of the tax jurisdictions resulting from these examinations. During 2011, the IRS completed an examination of the Company's U.S. federal tax return for the 2009 tax year with no material adjustments. The Company reversed its previously unrecognized federal tax benefit of $3.2 million during 2011, as a result of both the completion of the IRS examination and the expiration of the statute of limitations for 2007. As of December 31, 2011, there were unrecognized state tax benefits of $8.4 million.