Income Taxes (Tables)

12 Months Ended

Dec. 31, 2014

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



	Year Ended December 31,
	2014			2013			2012
GAAP net income (loss) from REIT operations	$	68,796		$	(62,513	)	$	(125,088	)
Book/tax differences, net:
Depreciation and amortization^(a)	1,831			2,173			2,084
Noncontrolling interests	329			(4,017		)	4,112
Gain/loss differences from dispositions	(99,946		)	(2,032		)	(30,747		)
Impairment loss not deductible for tax	—			28,795			1,335
Conversion costs	(3,233		)	(2,099		)	31,197
Other	(1,674		)	8,453			(9,226		)
Tax loss^(b)	$	(33,897	)	$	(31,240	)	$	(126,333	)


(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 (net of capital gains).

Schedule of Deferred Tax Asset

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



	December 31,
	2014			2013
Accumulated net operating losses of TRSs	$	107,027		$	119,355
Tax property basis in excess of book	952			1,017
Accrued employee benefits not deductible for tax	3,883			3,477
Management fee recognition	81			464
Foreign exchange	—			4,905
Capitalized TRS start-up costs	6,399			1,893
Other	1,261			701
Gross deferred tax asset	119,603			131,812
Valuation allowance	(119,603		)	(131,812		)
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:



	2014				2013				2012
	Amount			%	Amount			%	Amount			%
Preferred Stock – Series A
Dividend income	$	—		—	$	—		—	$	—		—
Return of capital	1.95		^(c)	100.00	1.95		^(b)	100.00	5.3625		^(a)	100.00
	$	1.95		100.00	$	1.95		100.00	$	5.3625		100.00
Preferred Stock – Series C
Dividend income	$	—		—	$	—		—	$	—		—
Return of capital	2.00		^(c)	100.00	2.00		^(b)	100.00	5.50		^(a)	100.00
	$	2.00		100.00	$	2.00		100.00	$	5.50		100.00
Common Stock
Dividend income	$	—		—	$	—		—	$	—		—
Return of capital	0.08		^(c)	100.00	—			—	—			—
	$	0.08		100.00	$	—		—	$	—		—


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


(b)	Fourth quarter 2012 preferred dividends were paid January 31, 2013, and were treated as 2013 distributions for tax purposes.


(c)	Fourth quarter 2013 preferred and common dividends were paid January 30, 2014, and were treated as 2014 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 (in thousands):



	Year Ended December 31,
	2014			2013			2012
GAAP consolidated net income (loss) attributable to FelCor LP	$	92,236		$	(62,001	)	$	(128,849	)
Loss (income) allocated to FelCor LP unitholders	(137		)	497			842
GAAP consolidated net income (loss) attributable to FelCor	92,099			(61,504		)	(128,007		)
GAAP net loss (income) from REIT operations	(68,796		)	62,513			125,088
GAAP net income (loss) of taxable subsidiaries	23,303			1,009			(2,919		)
Taxes related to joint venture transaction	5,761			—			—
Gain/loss differences from dispositions	—			—			(407		)
Depreciation and amortization^(a)	(461		)	1,646			404
Employee benefits not deductible for tax	(101		)	3,914			363
Management fee recognition	(1,151		)	(1,245		)	(1,715		)
Cancellation of debt	(3,188		)	—			—
Foreign exchange	—			—			12,907
Capitalized TRS start-up costs	11,859			4,981			—
Other book/tax differences	181			2,754			4,884
Tax income of taxable subsidiaries before utilization of net operating losses	36,203			13,059			13,517
Utilization of net operating loss	(36,203		)	(13,059		)	(13,517		)
Net tax income of taxable subsidiaries	$	—		$	—		$	—


(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.