What is Bw Premier Collection required to do regarding uncertain tax positions?
Bw_Premier_Collection Franchise · 2025 FDDAnswer from 2025 FDD Document
rs ended November 30, 2029, and 2030, respectively.
The Company reviews uncertain tax positions taken, or expected to be taken, in the course of preparing the Company's tax returns to determine whether the tax positions are more likely than not of being sustained by the applicable tax authority. Management of the Company is required to analyze all open tax years, as defined by the statutes of limitations for all major jurisdictions, which include federal, state, and foreign. As of November 30, 2024 and 2023, the Company has not recognized any asset or liability for unrecognized income tax benefits or liabilities. It is the Company's policy to recognize interest and penalties related to uncertain tax positions as a component of the income tax provision.
(o) Revenue Recognition
Fees, dues and assessments
Fees, dues and assessments are established by the membership and the Board of Directors to compensate the Company for providing services to Members, soft brand licensees, SureStay franchisees, and WorldHotels licensees. The Company has performance obligations to provide hotel support and marketing, and a license to our hotel system intellectual property for the use of our brand names.
Source: Item 23 — Receipts (FDD pages 54–203)
What This Means (2025 FDD)
According to the 2025 FDD, Bw Premier Collection reviews uncertain tax positions taken, or expected to be taken, when preparing tax returns to determine if these positions are more likely than not to be sustained by tax authorities. The company's management must analyze all open tax years, defined by the statutes of limitations, across major jurisdictions including federal, state, and foreign. As of November 30, 2024 and 2023, Bw Premier Collection has not recognized any assets or liabilities for unrecognized income tax benefits or liabilities.
Bw Premier Collection's policy is to recognize interest and penalties related to uncertain tax positions as part of the income tax provision. This means that any potential interest or penalties resulting from tax audits or disputes are accounted for within the company's overall income tax expenses.
As of November 30, 2024, Bw Premier Collection had foreign Net Operating Loss (NOL) carryforwards of $15.5 million and U.S. Foreign Tax Credit (FTC) carryforwards of $0.6 million. $1.9 million of the foreign NOLs are subject to expiration beginning in 2029, while the remaining $13.6 million do not expire. The FTC carryforwards, generated in 2019 and 2020, will expire in 2029 and 2030, respectively. The company has provided a valuation allowance against net deferred tax assets for certain foreign loss entities, as the realization of these assets is not considered more likely than not to occur.