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 continue 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 annual taxable income to our stockholders, excluding net capital gain. As a REIT, generally we will not be subject to U.S. federal and state corporate income taxes on that portion of our annual taxable income that is distributed to our stockholders. If we fail to qualify for taxation as a REIT in any taxable year, we will be

subject to U.S. federal and state corporate income taxes at regular corporate income tax rates and may not be able to qualify as a REIT for four subsequent taxable years. Even if we qualify to be treated as a REIT, we may be subject to certain state, local and foreign taxes on our income and property, and to U.S. federal and state corporate income and excise taxes on our undistributed taxable income. Our 2018 tax provision included approximately $77 million of U.S. federal and state corporate income taxes that we paid on long-term capital gain generated in 2018 that we chose to retain rather than to distribute to our stockholders.

As a result of legislation enacted by the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act in 2020, net operating losses generated in 2018, 2019, and 2020 may be carried back up to five years in order to procure a refund of U.S. federal corporate income taxes previously paid. Any net operating loss not carried back pursuant to these rules may be carried forward indefinitely, subject to an annual limit on the use thereof of 80% of annual taxable income. We recently filed refund claims to recover approximately $57 million of U.S. federal income taxes that we paid in 2017 through 2019, which is included in other assets on our consolidated balance sheet as of December 31, 2020.

Set forth below is a table that documents our domestic and foreign tax attributes at December 31, 2020:

Type	Jurisdiction	Amount (in millions)		Expiration
Net operating loss	U.S. Federal	$	487	None
Capital loss	U.S. Federal and State		37	2023
General business credit	U.S. Federal		1	Through 2040
Net operating loss	U.S. State		827	Various
Net operating loss	Brazil		14	None
Net operating loss	Canada		20	Through 2040
Capital loss	Canada		5	None

We have recorded a 100% valuation allowance of approximately $9 million against the deferred tax asset related to our domestic capital loss carryover and a 100% valuation allowance of approximately $5 million against the deferred tax asset related to certain of our foreign net operating loss and capital loss carryovers as of December 31, 2020. We also have recorded a valuation allowance of approximately $5 million against the deferred tax asset related to our accumulated other comprehensive income (“AOCI”) foreign exchange net losses. The net increase of our valuation allowance for the year ended December 31, 2020 is approximately $6 million from the year ended December 31, 2019.

The primary components of our net deferred tax assets are as follows (in millions):

	As of December 31,
	2020			2019
Deferred tax assets
Net operating losses, general business credits, and capital loss carryovers	$	172		$	16
Property and equipment		3			3
Deferred revenue and expenses		17			20
Foreign exchange net losses (AOCI)		12			12
Total gross deferred tax assets		204			51
Less: Valuation allowance		(19	)		(13	)
Total deferred tax assets, net of valuation allowance	$	185		$	38
Deferred tax liabilities
Investments in domestic affiliates		(1	)		(6	)
Total gross deferred tax liabilities		(1	)		(6	)
Net deferred tax assets	$	184		$	32

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 $19 million, of $185 million.

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

	Year ended December 31,
	2020			2019		2018
U.S. income (loss)	$	(945	)	$	949	$	887
Foreign income (loss)		(16	)		13		414
Total	$	(961	)	$	962	$	1,301

The income tax provision (benefit) for continuing operations consists of (in millions):

		Year ended December 31,
		2020			2019		2018
Current	—Federal	$	(57	)	$	14	$	79
	—State		1			6		30
	—Foreign		1			3		37
			(55	)		23		146
Deferred	—Federal		(96	)		3		2
	—State		(63	)		1		1
	—Foreign		(6	)		3		1
			(165	)		7		4
Income tax provision (benefit) – continuing operations		$	(220	)	$	30	$	150

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

	Year ended December 31,
	2020			2019			2018
Statutory federal income tax provision (benefit)	$	(202	)	$	202		$	273
Adjustment for nontaxable (income) loss of Host Inc.		34			(182	)		(192	)
Adjustment for net operating loss carryback to 2017-2019		18			—			—
State income tax provision (benefit), net		(62	)		7			31
Change to uncertain tax provision		(3	)		(3	)		—
Foreign income tax provision (benefit)		(5	)		6			38
Income tax provision (benefit)	$	(220	)	$	30		$	150

Cash paid for income taxes, net of refunds received, was immaterial in 2020, and $93 million and $82 million in 2019 and 2018, respectively.

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

	2020			2019
Balance at January 1	$	8		$	11
Reduction of unrecognized tax benefits due to expiration of statute of limitations		(3	)		(3	)
Balance at December 31	$	5		$	8

All of such uncertain tax position amounts, if recognized, would impact our reconciliation between the income tax provision (benefit) calculated at the statutory U.S. federal corporate income tax rate of 21% and the actual income tax provision (benefit) recorded each year.

We expect a decrease to the balance of unrecognized tax benefits within 12 months of the reporting date of approximately $4 million. As of December 31, 2020, the tax years that remain subject to examination by major tax jurisdictions generally include 2017-2020. There were no material interest or penalties recorded for the years ended December 31, 2020, 2019, and 2018.