Treatment of Carbon Emission Units for REIT

December 22, 2017

In Private Letter Ruling (“PLR”) 201751011 issued on December 22, 2017, the Internal Revenue Service (“IRS”) revoked and modified parts of PLR 201123003 issued on March 4, 2011 regarding the treatment of carbon emission units (“Units”) for a real estate investment trust (“REIT”). Under Income Tax Regulations Section 1.856-10(f),1 the Units do not qualify as real estate assets for the asset test under Sections 856(c)(5) and 856(c)(4)(A) because the Units can be sold separately from the land to which they relate.

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Cockram Construction, Inc

Cockram Construction, Inc. operates in Australia, Asia and the Americas. We are a multidisciplinary construction services business with a heritage dating back to 1861.

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Cockram Construction, Inc

Cockram Construction, Inc. operates in Australia, Asia and the Americas. We are a multidisciplinary construction services business with a heritage dating back to 1861.

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