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Income Taxes
 12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
We elected to be taxed as a REIT under Sections 856 through 860 of the Internal Revenue Code commencing with our taxable year beginning January 1, 1999. To continue to qualify as a REIT, we must meet a number of organizational and operational requirements, including a requirement that we distribute at least 90% of our annual taxable income to our stockholders, excluding net capital gain. As a REIT, generally we will not be subject to U.S. federal and state corporate income taxes on that portion of our annual taxable income that is distributed to our stockholders. If we fail to qualify for taxation as a REIT in any taxable year, we will be subject to U.S. federal and state corporate income taxes at regular corporate income tax rates and may not be able to qualify as a REIT for four subsequent taxable years. Even if we qualify to be treated as a REIT, we may be subject to certain state, local and foreign taxes on our income and property, and to U.S. federal and state corporate income and excise taxes on our undistributed taxable income.
Set forth below is a table that documents our domestic and foreign income tax attributes at December 31, 2024:
TypeJurisdictionAmount (in millions)
Tax Year Expiration
Net operating lossU.S. Federal$576 None
Capital lossU.S. Federal and States2 2028
Net operating lossU.S. States901 Various
Net operating lossBrazil19 None
Net operating lossCanada7 Through 2042
Capital lossCanada5 None
General business creditU.S. Federal4 2044
We have recorded a 100% valuation allowance of approximately $5 million against the deferred tax asset related to certain of our foreign capital loss carryovers as of December 31, 2024. We also have recorded a valuation allowance of approximately $5 million against the deferred tax asset related to our accumulated other comprehensive income (“AOCI”) foreign exchange net losses. There was a decrease of our valuation allowance for the year ended December 31, 2024 from the year ended December 31, 2023, of approximately $8 million, due to the expiration of capital losses.
The primary components of our net deferred tax assets are as follows (in millions):
 As of December 31,
20242023
Deferred tax assets
Net operating losses, general business credits, and capital loss carryovers$182 $205 
Investments in domestic affiliates1 — 
Property and equipment2 3 
Deferred revenue and expenses30 20 
Foreign exchange net losses (AOCI)12 12 
Total gross deferred tax assets227 240 
Less: Valuation allowance(10)(18)
Total deferred tax assets, net of valuation allowance$217 $222 
Deferred tax liabilities
Investments in domestic affiliates— (1)
Total gross deferred tax liabilities— (1)
Net deferred tax assets$217 $221 
We believe that it is more likely than not that the results of future operations will generate sufficient taxable income in order to realize our total deferred tax assets, net of a valuation allowance of $10 million, of $217 million.
Our U.S. and foreign income from continuing operations before income taxes were as follows (in millions):
 Year ended December 31,
202420232022
U.S. income$697 $768 $659 
Foreign income24 20 10 
Total$721 $788 $669 
Income tax provision for continuing operations consists of (in millions):
 Year ended December 31,
202420232022
Current—Federal$— $3 $3 
—State2 3 2 
—Foreign4 4 1 
6 10 6 
Deferred—Federal4 15 13 
—State3 10 5 
—Foreign1 1 2 
8 26 20 
Income tax provision - continuing operations$14 $36 $26 
The differences between the income tax provision calculated at the statutory U.S. federal corporate income tax rate of 21% and the actual income tax provision recorded for continuing operations are as follows (in millions):
 Year ended December 31,
202420232022
Statutory federal income tax provision$151 $165 $140 
Adjustment for nontaxable income of Host Inc.(147)(147)(124)
State income tax provision, net 5 13 7 
Foreign income tax provision5 5 3 
Total$14 $36 $26 
Cash taxes activity included a net payment of $11 million and $12 million in 2024 and 2023, respectively, and a net refund of $19 million in 2022.
Our unrecognized tax benefits remained unchanged at $1 million for each of the years ended December 31, 2024 and 2023. All of such uncertain tax position amounts, if recognized, would impact our reconciliation between the income tax provision calculated at the statutory U.S. federal corporate income tax rate of 21% and the actual income tax provision recorded each year.
As of December 31, 2024, the tax years that remain subject to examination by major tax jurisdictions generally include 2021-2024. There were no material interest or penalties recorded for the years ended December 31, 2024, 2023 and 2022.