Income Taxes (Tables)

12 Months Ended

Dec. 31, 2016

The following table reconciles REIT GAAP net income (loss) to taxable income (loss) (in thousands):



	Year Ended December 31,
	2016			2015			2014
GAAP net income (loss) from REIT operations	$	(21,332	)	$	(21,838	)	$	68,796
Book/tax differences, net:
Dividend income from TRS	25,650			24,809			—
Depreciation and amortization^(a)	19,582			3,937			1,831
Noncontrolling interests	(93		)	(400		)	329
Gain/loss differences from dispositions	(16,572		)	18,335			(99,946		)
Impairment loss not deductible for tax	26,459			20,861			—
Conversion costs	(3,233		)	(3,233		)	(3,233		)
Other	(446		)	1,505			(1,674		)
Tax income (loss)^(b)	$	30,015		$	43,976		$	(33,897	)


(a)	Book/tax differences in depreciation and amortization principally result from differences in depreciable lives and accelerated depreciation methods.


(b)	The dividend distribution requirement is 90% of any taxable income (net of capital gains). For 2016 and 2015, our distributions were in excess of 100% of taxable income.

Schedule of Deferred Tax Asset

Our TRSs had a deferred tax asset, on which we had a 100% valuation allowance, primarily comprised of the following (in thousands):



	December 31,
	2016			2015
Accumulated net operating losses of TRSs	$	94,219		$	98,367
Tax property basis compared to book	4,844			(4,518		)
Accrued employee benefits not deductible for tax	4,966			4,889
Historic tax credits^(a)	19,357			25,375
Other	26			109
Gross deferred tax asset	123,412			124,222
Valuation allowance	(123,412		)	(124,222		)
Deferred tax asset after valuation allowance	$	—		$	—

(a)

Because of the completion of construction at The Knickerbocker in 2015, one of our TRSs became entitled to the future benefits of historic tax credits that vest over a five year period and do not expire. Historic tax credits for 2015 reflect both federal and state credits. Upon the filing of the state return for 2015 in 2016, the state credit became refundable. Historic tax credits for 2016 reflect federal credits only.

Schedule of Characterization of Cash Dividends Distrubuted

For income tax purposes, dividends paid consist of ordinary income, capital gains, return of capital or a combination thereof. Dividends paid per share were characterized, in accordance with the requirements under the Internal Revenue Code, as follows:



	2016				2015				2014
	Amount			%	Amount			%	Amount			%
Preferred Stock – Series A
Capital gains	$	—		—	$	1.23		63.08	$	—		—
Dividend income	1.03			52.82	0.72			36.92	—			—
Non-dividend distribution	0.92			47.18	—			—	1.95			100.00
	$	1.95	^(a)	100.00	$	1.95	^(b)	100.00	$	1.95	^(c)	100.00
Preferred Stock – Series C
Capital gains	$	—		—	$	0.63		63.00	$	—		—
Dividend income	—			—	0.37			37.00	—			—
Non-dividend distribution	—			—	—			—	2.00			100.00
	$	—		—	$	1.00	^(b)	100.00	$	2.00	^(c)	100.00
Common Stock
Capital gains	$	—		—	$	—		—	$	—		—
Dividend income	—			—	—			—	—			—
Non-dividend distribution	0.24			100.00	0.16			100.00	0.08			100.00
	$	0.24	^(a)	100.00	$	0.16	^(b)	100.00	$	0.08	^(c)	100.00


(a)	Fourth quarter 2015 preferred and common distributions were paid January 29, 2016, and were treated as 2016 distributions for tax purposes.


(b)	Fourth quarter 2014 preferred and common distributions were paid January 29, 2015, and were treated as 2015 distributions for tax purposes.


(c)	Fourth quarter 2013 preferred and common distributions were paid January 30, 2014, and were treated as 2014 distributions for tax purposes.

Taxable REIT Subsidiaries [Member]

Income Taxes [Line Items]

Schedule of Income Tax Reconciliation

The following table reconciles our TRSs’ GAAP net income (loss) to federal taxable income (in thousands):



	Year Ended December 31,
	2016			2015			2014
GAAP consolidated net income (loss) attributable to FelCor LP	$	3,405		$	(9,059	)	$	92,236
Loss (income) allocated to FelCor LP unitholders	93			194			(137		)
GAAP consolidated net income (loss) attributable to FelCor	3,498			(8,865		)	92,099
GAAP net loss (income) from REIT operations	21,332			21,838			(68,796		)
GAAP net income of taxable subsidiaries	24,830			12,973			23,303
Taxes related to joint venture transaction	—			—			5,761
Gain/loss differences from dispositions	—			(872		)	—
Depreciation and amortization^(a)	(12,437		)	(1,877		)	(461		)
Employee benefits not deductible for tax	(2,965		)	(588		)	(101		)
Management fee recognition	—			(107		)	(1,151		)
Cancellation of debt	—			—			(3,188		)
Capitalized TRS start-up costs	—			—			11,859
Other book/tax differences	386			3,827			181
Federal tax income of taxable subsidiaries before utilization of net operating losses	9,814			13,356			36,203
Utilization of net operating loss	(9,814		)	(13,356		)	(36,203		)
Net federal tax income of taxable subsidiaries	$	—		$	—		$	—


(a)	The changes in book/tax differences in depreciation and amortization principally result from book and tax basis differences, differences in depreciable lives and accelerated depreciation methods.