IRS PLR: Carbon Offset Credit Income Qualifying Income (IRC §856)

The IRS has issued a private letter ruling on Section 856 concluding that income from the issuance of Offsets will be considered qualifying income under Section 856, and that income with respect to the issuance of Offsets will accrue under section 451 upon the earliest of the following events to occur: 1) Offsets are earned; 2) Offsets are received; or 3) Offsets are due. [PLR 202536025]

This story was produced by Bloomberg Tax Automation, and edited by Bloomberg Tax staff.