The IRS audited Hyatt for the tax years 2009 – 2011 and found that it wasn’t paying tax on loyalty program revenue. It didn’t include the revenue received for what was then Gold Passport (now World of Hyatt) in income, and didn’t include payments from the program as expenses. It just ignored the program, even though it collected money and invested it earning a return.
The IRS wanted Hyatt to not only pay up for those years but to go all the way back to the beginning of the program in 1987, with a quarter of a billion dollars of income at issue and a tax deficiency of $65 million.