| 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 year ended December 31, 2016, 2015 and 2014, respectively, are as follows:
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Year Ended December 31, |
|
|
2016 |
|
2015 |
|
2014 |
U.S. current income tax benefit |
|
$ |
2,306,512 |
|
|
$ |
12,861 |
|
|
$ |
24,805 |
|
U.S. deferred income tax expense |
|
47,957,169 |
|
|
(5,625,436 |
) |
|
5,549,517 |
|
Foreign current income tax expense |
|
3,594,014 |
|
|
3,878,855 |
|
|
1,674,407 |
|
Foreign deferred income tax expense |
|
27,176 |
|
|
144,634 |
|
|
265,465 |
|
Total |
|
$ |
53,884,871 |
|
|
$ |
(1,589,086 |
) |
|
$ |
7,514,194 |
|
Foreign tax credits may be applied for up to five years. Tax credits must be utilized five years subsequent to the distribution of the underlying earnings. As of December 31, 2016, the distributions have not yet occurred.
A reconciliation of the statutory federal income tax amount to the recorded expense is as follows:
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Year Ended December 31, |
|
|
2016 |
|
2015 |
|
2014 |
Loss before income taxes |
|
$ |
(34,523,124 |
) |
|
$ |
(28,820,500 |
) |
|
$ |
5,503,646 |
|
Statutory income tax rate |
|
35 |
% |
|
35 |
% |
|
35 |
% |
Expected income tax expense |
|
(12,083,093 |
) |
|
(10,087,175 |
) |
|
1,926,276 |
|
Income earned as non-taxable entity (See Note 2) |
|
13,750,827 |
|
|
— |
|
|
— |
|
Effect due to change to C corporation (See Note 2) |
|
53,088,861 |
|
|
— |
|
|
— |
|
Change in entity status |
|
— |
|
|
(4,792,243 |
) |
|
6,379,117 |
|
Non taxable entity |
|
— |
|
|
15,455,772 |
|
|
713,106 |
|
Other permanent differences |
|
209,546 |
|
|
— |
|
|
— |
|
State tax expenses |
|
21,181 |
|
|
— |
|
|
— |
|
Change in tax rate |
|
(24,803 |
) |
|
— |
|
|
— |
|
Foreign income tax rate differential |
|
(1,077,648 |
) |
|
(1,369,575 |
) |
|
(2,355,816 |
) |
Other |
|
— |
|
|
(795,865 |
) |
|
851,511 |
|
Total |
|
$ |
53,884,871 |
|
|
$ |
(1,589,086 |
) |
|
$ |
7,514,194 |
|
Deferred tax liabilities attributable to the Company consisted of the following:
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Year Ended December 31, |
|
|
2016 |
|
2015 |
Deferred tax assets: |
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|
|
|
Allowance for doubtful accounts |
|
$ |
1,892,761 |
|
|
$ |
— |
|
Deferred stock compensation |
|
1,686,671 |
|
|
— |
|
Accrued liabilities |
|
746,132 |
|
|
— |
|
Other |
|
1,785,999 |
|
|
86,580 |
|
Deferred tax assets |
|
6,111,563 |
|
|
86,580 |
|
|
|
|
|
|
Deferred tax liabilities: |
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|
|
|
Property and equipment |
|
$ |
(42,525,793 |
) |
|
$ |
(1,484,350 |
) |
Intangible assets |
|
(7,662,590 |
) |
|
— |
|
Unrepatriated foreign earnings |
|
(3,451,110 |
) |
|
— |
|
Other |
|
(142,859 |
) |
|
(63,189 |
) |
Deferred tax liabilities |
|
(53,782,352 |
) |
|
(1,547,539 |
) |
Net deferred tax liability |
|
$ |
(47,670,789 |
) |
|
$ |
(1,460,959 |
) |
|
|
|
|
|
Reflected in accompanying balance sheet as: |
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|
|
|
Deferred income taxes |
|
$ |
(47,670,789 |
) |
|
$ |
(1,460,959 |
) |
|