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Income Taxes
9 Months Ended
Sep. 30, 2019
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes

We are organized in conformity with the requirements for qualification and taxation as a REIT under the Internal Revenue Code of 1986, as amended (the “Code”) and, accordingly, we have not provided for U.S. federal income tax on our REIT taxable income that we distribute to our stockholders. We have elected to treat our subsidiaries that participate in certain non-REIT qualifying activities, and our foreign subsidiaries, as TRSs. As such, we have provided for their federal, state and foreign income taxes.

In the second quarter of 2019, we had recorded a provision for uncertain tax positions of $4.5 million to correct an error related to prior open tax years. In the third quarter of 2019, pursuant to an audit for the 2016 tax year, the Internal Revenue Service has issued a Notice of Proposed Adjustment, increasing our tax liability by $2.2 million, which represents a settlement of the $4.5 million provision for uncertain tax positions recorded in the second quarter of 2019.

Tax years 2016 to present are open for examination by the tax authorities. New York State has concluded an audit of our 2014 tax year without proposing any adjustments.

Our effective income tax rate represents a combined annual effective tax rate for federal, state, local and foreign taxes applied to interim operating results.

In the three and nine months ended September 30, 2019 and 2018, our effective tax rate differed from the U.S. federal statutory income tax rate primarily due to our REIT status, including the dividends paid deduction, the impact of state and local taxes, and the effect of foreign operations.