Income Taxes (Tables)

12 Months Ended

Dec. 31, 2013

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



	Year Ended December 31,
	2013			2012			2011
GAAP net loss from REIT operations	$	(62,513	)	$	(125,088	)	$	(127,709	)
Book/tax differences, net:
Depreciation and amortization^(a)	2,173			2,084			6,183
Noncontrolling interests	(4,017		)	4,112			4,149
Gain/loss differences from dispositions	(2,032		)	(30,747		)	(30,502		)
Impairment loss not deductible for tax	28,795			1,335			12,303
Conversion costs	(2,099		)	31,197			—
Other	8,453			(9,226		)	(1,974		)
Tax loss^(b)	$	(31,240	)	$	(126,333	)	$	(137,550	)


(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.

Schedule of Deferred Tax Asset

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



	December 31,
	2013			2012
Accumulated net operating losses of TRS	$	119,355		$	124,318
Tax property basis in excess of book	1,017			869
Accrued employee benefits not deductible for tax	3,477			2,291
Management fee recognition	464			932
Foreign exchange	4,905			4,905
Capitalized TRS start-up costs	1,893			—
Other	701			914
Gross deferred tax asset	131,812			134,229
Valuation allowance	(131,812		)	(134,229		)
Deferred tax asset after valuation allowance	$	—		$	—

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 as follows:




	2013				2012				2011
	Amount			%	Amount			%	Amount			%
Preferred Stock – Series A
Dividend income	$	—		—	$	—		—	$	—		—
Return of capital	1.95		^(c)	100.00	5.3625		^(b)	100.00	1.95		^(a)	100.00
	$	1.95		100.00	$	5.3625		100.00	$	1.95		100.00
Preferred Stock – Series C
Dividend income	$	—		—	$	—		—	$	—		—
Return of capital	2.00		^(c)	100.00	5.50		^(b)	100.00	2.00		^(a)	100.00
	$	2.00		100.00	$	5.50		100.00	$	2.00		100.00


(a)	Fourth quarter 2010 preferred distributions were paid January 31, 2011, and were treated as 2011 distributions for tax purposes.


(b)	Fourth quarter 2011 preferred distributions were paid January 31, 2012, and were treated as 2012 distributions for tax purposes.


(c)	Fourth quarter 2012 preferred distributions were paid January 31, 2013, and were treated as 2013 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 taxable income (loss) (in thousands):



	Year Ended December 31,
	2013			2012			2011
GAAP consolidated net loss attributable to FelCor LP	$	(62,001	)	$	(128,849	)	$	(130,543	)
Loss allocated to FelCor LP unitholders	497			842			689
GAAP consolidated net loss attributable to FelCor	(61,504		)	(128,007		)	(129,854		)
GAAP net loss from REIT operations	62,513			125,088			127,709
GAAP net income (loss) of taxable subsidiaries	1,009			(2,919		)	(2,145		)
Impairment loss not deductible for tax	—			—			946
Gain/loss differences from dispositions	—			(407		)	(7,841		)
Depreciation and amortization^(a)	1,646			404			1,389
Employee benefits not deductible for tax	3,914			363			(1,578		)
Management fee recognition	(1,245		)	(1,715		)	(1,717		)
Foreign exchange	—			12,907			—
Capitalized TRS start-up costs	4,981			—			—
Other book/tax differences	2,754			4,884			(552		)
Tax income (loss) of taxable subsidiaries before utilization of net operating losses	13,059			13,517			(11,498		)
Utilization of net operating loss	(13,059		)	(13,517		)	—
Net tax loss of taxable subsidiaries	—			$	—		$	(11,498	)


(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.