IRS PLR: REIT, Carbon Offset Credit Rulings Issued (IRC §856)

The IRS has issued a private letter ruling on Section 856 concluding that: 1) income from the issuance of carbon offset credits will be considered qualifying income under Sections 856(c)(2) and (3) for a real estate investment trust (REIT); and (2) income from reforestation grant payments will also be considered qualifying income under Sections 856(c)(2) and (3). [PLR 202536023]

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