| Income Taxes |
Income Taxes
As discussed in Note 1, the Partnership was converted into a limited liability company on October 12, 2016 and the membership interests in the limited liability company were contributed to the Company. As a result, the Company will file a consolidated return for the period October 12, 2016 through December 31, 2016. Prior to the conversion, the Partnership, other than Lodging, was not subject to corporate income taxes.
The components of income tax expense (benefit) attributable to the Company for the three months ended March 31, 2017 and 2016, are as follows:
|
|
|
|
|
|
|
|
|
|
|
|
Three Months Ended March 31, |
|
|
2017 |
|
2016 |
U.S. deferred income tax benefit |
|
$ |
(3,685,381 |
) |
|
$ |
— |
|
Foreign current income tax expense |
|
585,467 |
|
|
894,360 |
|
Foreign deferred income tax benefit |
|
(6,151 |
) |
|
— |
|
Total |
|
$ |
(3,106,065 |
) |
|
$ |
894,360 |
|
A reconciliation of the statutory federal income tax amount to the recorded expense is as follows:
|
|
|
|
|
|
|
|
|
|
|
|
Three Months Ended March 31, |
|
|
2017 |
|
2016 |
Loss before income taxes |
|
$ |
(8,042,579 |
) |
|
$ |
(20,236,074 |
) |
Statutory income tax rate |
|
35 |
% |
|
35 |
% |
Expected income tax benefit |
|
(2,814,903 |
) |
|
(7,082,626 |
) |
Non-taxable entity |
|
— |
|
|
8,260,791 |
|
Other permanent differences |
|
14,063 |
|
|
6,793 |
|
State tax benefit |
|
(452,372 |
) |
|
(2,055 |
) |
Foreign tax credit |
|
(698,289 |
) |
|
— |
|
Foreign earnings not in book income |
|
1,046,248 |
|
|
— |
|
Foreign income tax rate differential |
|
(174,511 |
) |
|
(270,813 |
) |
Other |
|
(26,301 |
) |
|
(17,730 |
) |
Total |
|
$ |
(3,106,065 |
) |
|
$ |
894,360 |
|
Deferred tax assets and liabilities attributable to the Company consisted of the following:
|
|
|
|
|
|
|
|
|
|
|
|
March 31, |
|
December 31, |
|
|
2017 |
|
2016 |
Deferred tax assets: |
|
|
|
|
Allowance for doubtful accounts |
|
$ |
1,891,392 |
|
|
$ |
1,892,761 |
|
Net operating loss carryforward |
|
2,280,696 |
|
|
— |
|
Deferred stock compensation |
|
1,697,536 |
|
|
1,686,671 |
|
Accrued liabilities |
|
601,449 |
|
|
746,132 |
|
Other |
|
1,765,362 |
|
|
1,785,999 |
|
Deferred tax assets |
|
8,236,435 |
|
|
6,111,563 |
|
|
|
|
|
|
Deferred tax liabilities: |
|
|
|
|
Property and equipment |
|
$ |
(40,901,822 |
) |
|
$ |
(42,525,793 |
) |
Intangible assets |
|
(6,890,355 |
) |
|
(7,662,590 |
) |
Unrepatriated foreign earnings |
|
(4,244,437 |
) |
|
(3,451,110 |
) |
Other |
|
(80,833 |
) |
|
(142,859 |
) |
Deferred tax liabilities |
|
(52,117,447 |
) |
|
(53,782,352 |
) |
Net deferred tax liability |
|
$ |
(43,881,012 |
) |
|
$ |
(47,670,789 |
) |
|
|
|
|
|
Reflected in accompanying balance sheet as: |
|
|
|
|
Deferred income taxes |
|
$ |
(43,881,012 |
) |
|
$ |
(47,670,789 |
) |
|