Income Taxes

For the three and nine months ended September 30, 2017 and September 30, 2016, the Company qualified to be taxed as a REIT under the Code for U.S. federal income tax purposes. As long as the Company qualifies as a REIT, the Company generally will not be subject to U.S. federal income taxes on its taxable income to the extent it annually distributes at least 100% of its taxable income to stockholders and does not engage in prohibited transactions. Certain activities the Company performs may produce income that will not be qualifying income for REIT purposes. The Company has designated its TRSs to engage in these activities. The tables below reflect the taxes accrued at the TRS level and the tax attributes included in the consolidated financial statements.

The income tax provision for the three and nine months ended September 30, 2017 and September 30, 2016 is comprised of the following components (dollar amounts in thousands):



	Three Months Ended September 30,						Nine Months Ended September 30,
	2017			2016			2017			2016
Current income tax expense	$	541		$	326		$	2,280		$	2,581
Deferred income tax (benefit) expense	(34		)	(163		)	(93		)	139
Total provision	$	507		$	163		$	2,187		$	2,720

Deferred Tax Assets and Liabilities

The major sources of temporary differences included in the deferred tax assets and their deferred tax effect as of September 30, 2017 and December 31, 2016 are as follows (dollar amounts in thousands):



	September 30, 2017			December 31, 2016
Deferred tax assets
Net operating loss carryforward	$	2,174		$	2,287
Net capital loss carryforward	—			1,123
GAAP/Tax basis differences	3,556			3,059
Total deferred tax assets ⁽¹⁾	5,730			6,469
Deferred tax liabilities
Deferred tax liabilities	200			303
Total deferred tax liabilities ⁽²⁾	200			303
Valuation allowance ⁽¹⁾	(5,248		)	(5,978		)
Total net deferred tax asset	$	282		$	188


⁽¹⁾	Included in receivables and other assets in the accompanying condensed consolidated balance sheets.


⁽²⁾	Included in accrued expenses and other liabilities in the accompanying condensed consolidated balance sheets.

As of September 30, 2017, the Company, through wholly owned TRSs, had incurred net operating losses in the aggregate amount of approximately $4.8 million. The Company’s carryforward net operating losses will expire between 2033 and 2037 if they are not offset by future taxable income. At September 30, 2017, the Company has recorded a valuation allowance against certain deferred tax assets as management does not believe that it is more likely than not that these deferred tax assets will be realized.

The Company files income tax returns with the U.S. federal government and various state and local jurisdictions. The Company's federal, state and city income tax returns are subject to examination by the Internal Revenue Service and related tax authorities generally for three years after they were filed. The Company has assessed its tax positions for all open years and concluded that there are no material uncertainties to be recognized.

In addition, based on the Company’s evaluation, the Company has concluded that there are no significant uncertain tax positions requiring recognition in the Company’s financial statements.