Income Taxes (Tables)

12 Months Ended

Dec. 31, 2015

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



	Year Ended December 31,
	2015			2014			2013
GAAP net income (loss) from REIT operations	$	(21,838	)	$	68,796		$	(62,513	)
Book/tax differences, net:
Dividend income from TRS	24,809			—			—
Depreciation and amortization^(a)	3,937			1,831			2,173
Noncontrolling interests	(400		)	329			(4,017		)
Gain/loss differences from dispositions	18,335			(99,946		)	(2,032		)
Impairment loss not deductible for tax	20,861			—			28,795
Conversion costs	(2,881		)	(3,233		)	(2,099		)
Other	1,153			(1,674		)	8,453
Tax income (loss)^(b)	$	43,976		$	(33,897	)	$	(31,240	)


(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,
	2015			2014
Accumulated net operating losses of TRSs	$	98,367		$	107,027
Tax property basis compared to book	(4,518		)	952
Accrued employee benefits not deductible for tax	4,889			3,883
Management fee recognition	—			81
Historic tax credits^(a)	25,375			—
Capitalized TRS start-up costs	—			6,399
Other	109			1,261
Gross deferred tax asset	124,222			119,603
Valuation allowance	(124,222		)	(119,603		)
Deferred tax asset after valuation allowance	$	—		$	—

(a) Because of the completion of construction at The Knickerbocker in 2015, one of our TRSs became entitled to the future benefits of historic tax credits that vest over a five year period and do not expire.

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, in accordance with the requirements under the Code, as follows:



	2015				2014				2013
	Amount			%	Amount			%	Amount			%
Preferred Stock – Series A
Capital gains	$	1.23		63.08	$	—		—	$	—		—
Dividend income	$	0.72		36.92	$	—		—	$	—		—
Return of capital	—		^(c)	—	1.95		^(b)	100.00	1.95		^(a)	100.00
	$	1.95		100.00	$	1.95		100.00	$	1.95		100.00
Preferred Stock – Series C
Capital gains	$	0.63		63.00	$	—		—	$	—		—
Dividend income	$	0.37		37.00	$	—		—	$	—		—
Return of capital	—		^(c)	—	2.00		^(b)	100.00	2.00		^(a)	100.00
	$	1.00		100.00	$	2.00		100.00	$	2.00		100.00
Common Stock
Capital gains	$	—		—	$	—		—	$	—		—
Dividend income	$	—		—	$	—		—	$	—		—
Return of capital	0.16		^(c)	100.00	0.08			100.00	—			—
	$	0.16		100.00	$	0.08		100.00	$	—		—


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


(b)	Fourth quarter 2013 preferred and common dividends were paid January 30, 2014, and were treated as 2014 distributions for tax purposes.


(c)	Fourth quarter 2014 preferred and common dividends were paid January 29, 2015, and were treated as 2015 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 federal taxable income (in thousands):



	Year Ended December 31,
	2015			2014			2013
GAAP consolidated net income (loss) attributable to FelCor LP	$	(9,059	)	$	92,236		$	(62,001	)
Loss (income) allocated to FelCor LP unitholders	194			(137		)	497
GAAP consolidated net income (loss) attributable to FelCor	(8,865		)	92,099			(61,504		)
GAAP net loss (income) from REIT operations	21,838			(68,796		)	62,513
GAAP net income (loss) of taxable subsidiaries	12,973			23,303			1,009
Taxes related to joint venture transaction	—			5,761			—
Gain/loss differences from dispositions	(872		)	—			—
Depreciation and amortization^(a)	(1,877		)	(461		)	1,646
Employee benefits not deductible for tax	(588		)	(101		)	3,914
Management fee recognition	(107		)	(1,151		)	(1,245		)
Cancellation of debt	—			(3,188		)	—
Capitalized TRS start-up costs	—			11,859			4,981
Other book/tax differences	3,827			181			2,754
Federal tax income of taxable subsidiaries before utilization of net operating losses	13,356			36,203			13,059
Utilization of net operating loss	(13,356		)	(36,203		)	(13,059		)
Net federal 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.