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 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 taxable income to our stockholders, excluding net capital gain. As a REIT, generally we will not be subject to federal and state corporate income tax on that portion of our taxable income that currently is distributed to our stockholders. If we fail to qualify for taxation as a REIT in any taxable year, we will be subject to federal and state corporate income taxes at regular corporate rates and may not be able to qualify as a REIT for four subsequent taxable years. Even if we qualify for taxation as a REIT, we may be subject to certain state, local and foreign taxes on our income and property, and to federal and state income and excise taxes on our undistributed taxable income. Our 2018 tax provision includes approximately $77 million of U.S. federal and state corporate income tax that we paid on long-term capital gain generated in 2018 that we chose to retain rather than distribute to our stockholders.

We have recorded a 100% valuation allowance of approximately $9 million against the deferred tax asset related to our domestic capital loss carryover as of December 31, 2018. The net decrease of our valuation allowance for the year ending December 31, 2018 is approximately $16 million from the year ending December 31, 2017. The primary components of our net deferred tax assets are as follows (in millions):

	As of December 31,
	2018			2017
Deferred tax assets
Net operating loss and capital loss carryovers	$	17		$	34
Property and equipment		3			3
Deferred revenue and expenses		23			27
Foreign exchange net losses (AOCI)		12			12
Total gross deferred tax assets		55			76
Less: Valuation allowance		(11	)		(27	)
Total deferred tax assets, net of valuation allowance	$	44		$	49
Deferred tax liabilities
Investments in domestic affiliates		(5	)		(8	)
Total gross deferred tax liabilities		(5	)		(8	)
Net deferred tax assets	$	39		$	41

At December 31, 2018, we have aggregate gross domestic and foreign net operating loss and capital loss carryovers of approximately $60 million. We have deferred tax assets related to these domestic and foreign loss carryovers of approximately $17 million, with a valuation allowance of approximately $11 million. Our Canadian net operating loss carryovers expire through 2035, and our Canadian capital loss carryover has no expiration date. Our domestic capital loss carryover expires in 2023. Our Brazil net operating loss carryovers have no expiration date. 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 $11 million, of $44 million.

Our U.S. and foreign income from continuing operations before income taxes was as follows (in millions):

	Year ended December 31,
	2018		2017		2016
U.S. income	$	887	$	593	$	763
Foreign income		414		58		48
Total	$	1,301	$	651	$	811

The provision for income taxes from continuing operations consists of (in millions):

		Year ended December 31,
		2018		2017		2016
Current	—Federal	$	79	$	17	$	—
	—State		30		6		1
	—Foreign		37		19		12
			146		42		13
Deferred	—Federal		2		32		24
	—State		1		4		6
	—Foreign		1		2		(3	)
			4		38		27
Income tax provision – continuing operations		$	150	$	80	$	40

The differences between the income tax provision calculated at the statutory U.S. federal income tax rate of 21% in 2018 (35% in 2017 and 2016) and the actual income tax provision recorded for continuing operations are as follows (in millions):

	Year ended December 31,
	2018			2017			2016
Statutory federal income tax provision	$	273		$	228		$	284
Adjustment for nontaxable income of Host Inc.		(192	)		(190	)		(260	)
State income tax provision, net		31			10			7
Remeasurement of domestic net deferred tax assets		—			11			—
Foreign income tax provision		38			21			9
Income tax provision	$	150		$	80		$	40

Cash paid for income taxes, net of refunds received, was $82 million, $40 million, and $15 million in 2018, 2017, and 2016, respectively.

A reconciliation of the beginning and ending balances of our unrecognized tax benefits is as follows (in millions):

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 income tax rate of 21% (35% in 2017) and the actual income tax provision recorded each year.

We expect a decrease to the balance of unrecognized tax benefits within 12 months of the reporting date of approximately $3 million. As of December 31, 2018, the tax years that remain subject to examination by major tax jurisdictions generally include 2015-2018. There were no material interest or penalties recorded for the years ended December 31, 2018, 2017, and 2016.