Income Taxes
The following table summarizes dividends declared during the three years ended December 31, 2017 and their related tax characterization.
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| | | | | | Tax Characterization of Dividends |
Year | | Dividends Declared Per Share | | Dividends Declared | | Ordinary Income Per Share | | Qualified Dividends | | Capital Gains Per Share |
8.125% Series A Cumulative Redeemable Preferred Stock Dividends | | | | | | | | | | |
2017 | | $ | 2.031250 |
| | $ | 4,468 |
| | $ | 2.031250 |
| | $ | — |
| | $ | — |
|
2016 | | $ | 2.031250 |
| | $ | 4,468 |
| | $ | 2.031250 |
| | $ | — |
| | $ | — |
|
2015 | | $ | 2.031250 |
| | $ | 4,468 |
| | $ | 2.031250 |
| | $ | — |
| | $ | — |
|
Common Stock Dividends | | | | | | | | | | |
2017 | | $ | 1.850000 |
| | $ | 84,726 |
| | $ | 1.850000 |
| | $ | — |
| | $ | — |
|
2016 | | $ | 1.600000 |
| | $ | 73,261 |
| | $ | 1.600000 |
| | $ | — |
| | $ | — |
|
2015 | | $ | 1.800000 |
| | $ | 90,232 |
| | $ | 1.800000 |
| | $ | — |
| | $ | — |
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We have distributed all of our 2017 taxable income within the allowable time frame, including the available spill-back provision, so that we will not be subject to Federal or state corporate income tax. We do not currently expect to incur any excise tax liability for the year ended December 31, 2017.
Based on our analysis of any potential uncertain income tax positions, we concluded that we do not have any uncertain tax positions that meet the recognition or measurement criteria as of December 31, 2017 and 2016. Our tax returns for tax years since 2014 are open to examination by the Internal Revenue Service (“IRS”).
RCS is taxable as a corporation under Subchapter C of the Internal Revenue Code, with which we filed a joint TRS election. As of December 31, 2017, RCS had Federal net operating loss (“NOL”) carryforwards of approximately $118 million, which can be carried forward for up to twenty years. The utilization of approximately $50 million of the NOL is subject to limitations imposed by the Internal Revenue Code. RCS sold its MSR holdings during the first quarter of 2017 and incurred approximately $14 million of capital loss, which can be carried forward for up to five years.
The Tax Cuts and Jobs Act (“TCJA”) signed into law during the fourth quarter of 2017 reduces the Corporate tax rate to
21% for tax years starting after December 31, 2017. As of December 31, 2017, RCS’s gross deferred tax assets associated with
the NOL and temporary differences other than the AMT credit carryforward, as reevaluated based on the new corporate tax rate
and estimated state effective rate, were approximately $31 million, with respect to which RCS has provided a full valuation allowance.
The valuation allowance previously provided on the AMT credit carryforward has been released due to the repeal of corporate AMT tax and the credit refund mechanism provided by TCJA. As a result, a deferred tax benefit of $0.6 million has been recorded in the consolidated statements of operations, and a corresponding income tax receivable is included in other assets on the consolidated balance sheets as of December 31, 2017.