Income Taxes

9 Months Ended

Sep. 30, 2011

Income Taxes

Income Taxes

Note 8.  Income Taxes

We have elected to be taxed as a real estate investment trust, or REIT, under the Internal Revenue Code of 1986, as amended, and, accordingly are generally not subject to federal and most state income taxation on our operating income provided we distribute our taxable income to our shareholders and meet certain organization and operating requirements.  We are subject to income tax in Canada, Puerto Rico and certain states despite our REIT status.  Further, we lease our managed hotels to our wholly owned TRSs that, unlike most of our other subsidiaries, file a separate consolidated tax return and are subject to federal, state and foreign income taxes.  Our consolidated income tax provision (or benefit) includes the income tax provision (or benefit) related to the operations of our TRSs and certain state and foreign income taxes incurred by us despite our REIT status.

During the three and nine months ended September 30, 2011, we recognized current tax expense of $621 and $1,188, respectively, which includes $50 and $120, respectively, of foreign taxes and $526 and $1,222, respectively, of certain state taxes that are payable without regard to our REIT status and TRS tax loss carry forwards. In addition, during the three and nine months ended September 30, 2011, we recognized a deferred tax expense (benefit) of $45 and ($154), respectively, related to a basis difference at our Puerto Rico hotel and Canadian tax losses available to offset future income.