6.	Income Taxes

We have recorded a 100% valuation allowance of approximately $44 million against the deferred tax asset related to the net operating loss and asset tax credit carryovers as of December 31, 2013 with respect to our hotel in Mexico. There is a $4 million valuation allowance against the deferred tax asset related to the net operating loss and capital loss carryovers as of December 31, 2013 with respect to our hotels in Canada. There is a $3 million valuation allowance related to the net operating loss incurred by our office in Rio de Janeiro. Finally, there is a $10 million valuation allowance against the deferred tax asset related to the net operating loss carryovers as of December 31, 2013 with respect to certain of our U.S. taxable REIT subsidiaries that acted as lessee pursuant to the terminated HPT leases. We expect that the remaining net operating loss and alternative minimum tax credit carryovers for U.S. federal income tax purposes will be realized. The net decrease and the net increase in the valuation allowance for the year ending December 31, 2013 and December 31, 2012 is approximately $2 million and $16 million, respectively. The primary components of our net deferred tax asset are as follows (in millions):

	As of December 31,
Deferred tax assets	2013			2012
Accrued related party interest	$	19		$	17
Net operating loss and capital loss carryovers		85			101
Alternative minimum tax credits		5			4
Property and equipment		4			4
Investments in domestic affiliates		3			3
Other		1			2
Deferred revenue		57			54
Total gross deferred tax assets		174			185
Less: Valuation allowance		(61	)		(63	)
Total deferred tax assets, net of valuation allowance	$	113		$	122
Deferred tax liabilities
Property and equipment		(21	)		(23	)
Investments in domestic and foreign affiliates		(6	)		(6	)
Other		(3	)		(3	)
Total gross deferred tax liabilities		(30	)		(32	)
Net deferred tax assets	$	83		$	90

At December 31, 2013, we have aggregate gross domestic and foreign net operating loss, capital loss and tax credit carryovers of approximately $250 million. We have deferred tax assets related to these loss and tax credit carryovers of approximately $85 million, with a valuation allowance of approximately $61 million. Our net operating loss carryovers expire through 2031, and our foreign capital loss carryovers have no expiration period. Our domestic alternative minimum tax credits have no expiration period and our foreign asset tax credits expire through 2017.

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

	Year ended December 31,
	2013		2012			2011
U.S. income (loss)	$	213	$	(22	)	$	(60	)
Foreign income		18		45			32
Total	$	231	$	23		$	(28	)

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

		Year ended December 31,
		2013		2012		2011
Current	—Federal	$	2	$	3	$	1
	—State		4		1		1
	—Foreign		9		10		8
			15		14		10
Deferred	—Federal		4		11		(11	)
	—State		1		1		(2	)
	—Foreign		1		5		2
			6		17		(11	)
Income tax provision (benefit) – continuing operations		$	21	$	31	$	(1	)

The total provision (benefit) for income taxes, including the amounts associated with discontinued operations, was $26 million, $32 million, and ($2) million in 2013, 2012, and 2011, respectively.

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

	Year ended December 31,
	2013			2012		2011
Statutory federal income tax provision (benefit) – continuing operations	$	81		$	8	$	(10	)
Adjustment for nontaxable (income) loss of Host Inc. – continuing operations		(77	)		4		—
State income tax provision (benefit), net		5			2		(1	)
Provision for uncertain tax positions		2			2		—
Foreign income tax provision		10			15		10
Income tax provision (benefit) – continuing operations	$	21		$	31	$	(1	)

Cash paid for income taxes, net of refunds received, was $17 million, $12 million, and $8 million in 2013, 2012, and 2011, respectively.

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

	2013		2012
Balance at January 1	$	3	$	5
Reduction due to expiration of certain statutes of limitation		—		(4	)
Other increases (decreases)		2		2
Balance at December 31	$	5	$	3

All of such uncertain tax position amount, if recognized, would impact our reconciliation between the income tax provision (benefit) calculated at the statutory U.S. federal income tax rate of 35% and the actual income tax provision (benefit) recorded each year.

We expect an increase to the balance of unrecognized tax benefits within 12 months of the reporting date of approximately $2 million. As of December 31, 2013, the tax years that remain subject to examination by major tax jurisdictions generally include 2010-2013.

There were no material interest or penalties recognized for the years ended December 31, 2013, 2012 and 2011.