INCOME TAX

The Company formed two TRSs, ACRC Lender W TRS LLC and ACRC Lender U TRS LLC, in December 2013 and March 2014, respectively, in order to issue and hold certain loans intended for sale. The income tax provision for the Company and the TRSs consisted of the following for the years ended December 31, 2016, 2015 and 2014 ($ in thousands):



	For the years ended December 31,
	2016		2015			2014
Current	$	21	$	(11	)	$	240
Deferred	—		—			—
Excise tax	209		—			—
Total income tax expense (benefit), including excise tax	$	230	$	(11	)	$	240

For the year ended December 31, 2016, the Company recorded an expense of $209 thousand for U.S. federal excise tax. Excise tax represents a 4% tax on a portion of the required amount of the Company’s ordinary income and net capital gains not distributed during the year. The annual expense is calculated in accordance with applicable tax regulations.

As of December 31, 2016, tax years 2013 through 2015 remain subject to examination by taxing authorities. The Company does not have any unrecognized tax benefits and the Company does not expect that to change in the next 12 months.