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Income Taxes
 12 Months Ended
Dec. 31, 2020
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
Current income tax expense represents the amounts expected to be reported on the Company’s income tax returns, and deferred tax expense or benefit represents the change in the net deferred tax assets and liabilities. The deferred tax assets and liabilities are determined based on the difference between the financial statement and tax bases of assets and liabilities as measured by the enacted tax rates that will be in effect when these differences reverse.

The Company accounts for income taxes using the asset and liability method. Under this method, deferred tax assets and liabilities are recognized for the estimated future tax consequences attributable to the differences between the financial statement carrying amounts of existing assets and liabilities and their respective income tax bases, and for net operating loss, capital loss and tax credit carryforwards. The deferred tax assets and liabilities are measured using the enacted income tax rates in effect for the year in which those temporary differences are expected to be realized or settled. The effect on the deferred tax assets and liabilities from a change in tax rates is recognized in earnings in the period when the net rate is enacted. However, deferred tax assets are recognized only to the extent that it is more likely than not that they will be realized based on consideration of all available evidence, including the future reversals of existing taxable temporary differences, future projected taxable income and tax planning strategies.

The components of the income tax provision are as follows (in thousands):
For the Years Ended December 31,
202020192018
Current:
Federal$— $— $— 
State(484)(3,067)(2,209)
Deferred:
Federal(45,438)3,987 (4,867)
State(6,048)2,831 (1,717)
Income tax (expense) benefit $(51,970)$3,751 $(8,793)

The provision for income taxes is different from the amount of income tax (expense) benefit that is determined by applying the applicable U.S. statutory federal income tax rate to pretax income as a result of the following differences (in thousands):
For the Years Ended December 31,
202020192018
Expected U.S. federal tax benefit (expense) at statutory rate$90,143 $(26,382)$(41,864)
Tax impact of REIT election(85,140)24,129 35,058 
Expected tax benefit (expense) at TRS5,003 (2,253)(6,806)
Change in valuation allowance(59,321)(297)542 
State income tax benefit (expense), net of federal benefit1,174 (2,367)(1,463)
Reassessment of acquired NOLs— 9,973 — 
Impact of rate changes349 332 (51)
Other permanent items(22)(117)(566)
Impact of provision to return/deferred adjustments847 (1,520)(449)
Income tax (expense) benefit$(51,970)$3,751 $(8,793)
Deferred income taxes represent the tax effect from continuing operations of the differences between the book and tax basis of the assets and liabilities. The deferred tax assets (liabilities) include the following (in thousands):
December 31, 2020December 31, 2019
Deferred tax liabilities:
Partnership basis$(2,453)$(977)
Prepaid expenses(1,157)(1,496)
Deferred tax liabilities$(3,610)$(2,473)
Deferred tax assets:
Property and equipment$2,619 $1,786 
Incentive and vacation accrual2,339 3,878 
Deferred revenue - key money966 994 
Allowance for doubtful accounts76 65 
Other202 421 
Net operating loss carryforwards71,831 57,109 
Federal historic tax credit824 824 
Wyndham guarantee5,384 10,192 
Valuation allowance(80,670)(21,349)
Deferred tax assets$3,571 $53,920 

Deferred tax assets are recognized only to the extent that it is more likely than not that they will be realized based on the consideration of all available evidence, including the future reversals of existing taxable temporary differences, future projected taxable income, and tax planning strategies. Valuation allowances are provided if, based upon the weight of the available evidence, it is more likely than not that some or all of the deferred tax assets will not be realized. The Company would record a valuation allowance to reduce its deferred tax assets to the amount that is most likely to be utilized in future periods to offset taxable income. Based upon the available objective evidence at December 31, 2020, the Company determined it was more likely than not that the deferred tax assets related to the net operating loss ("NOL") carryforwards of its primary TRS would not be utilized in future periods. The Company considered all available evidence, both positive and negative, including cumulative losses in recent years and its current forecast of future income in its analysis. As a result, the Company recorded a $59.3 million valuation allowance to fully reserve these deferred tax assets and recorded income tax expense totaling $52.0 million during the year ended December 31, 2020. As of December 31, 2020 and 2019, the Company had a valuation allowance of approximately $80.7 million and $21.3 million, respectively, related to NOL carryforwards, historic tax credits, and other deferred tax assets of its TRSs.

As discussed in Note 10, Commitments and Contingencies, the Company terminated its agreements with Wyndham effective December 31, 2019. The termination triggered the reassessment of the utilization of NOLs acquired in the merger with FelCor. As a result, the Company recorded a deferred tax benefit during the year ended December 31, 2019 to recognize additional deferred tax assets related to NOLs that would have otherwise expired absent the termination.

The Company’s NOLs will begin to expire in 2024 for federal tax purposes and 2020 to 2040 for state tax purposes. The Company's historic tax credits begin to expire in 2035. The annual utilization of these NOLs and tax credits is limited pursuant to federal and state tax laws.

The Company is subject to examination by U.S. federal and various state and local jurisdictions.  The tax years subject to examination vary by jurisdiction.  With few exceptions, as of December 31, 2020, the Company is no longer subject to U.S. federal or state and local tax examinations by tax authorities for the tax years of 2015 and before. 
The Company had no accruals for tax uncertainties as of December 31, 2020 and 2019.