IRS PLR: Carbon Storage Rights Payments Qualify as REIT Income (IRC §856)

December 22, 2025, 11:36 PM UTC

The IRS has published a private letter ruling on I.R.C. §856, clarifying that payments received by a real estate investment trust (REIT) for carbon storage rights constitute qualifying income, as either rents from real property, or gains from disposition of real property interests, based on whether the rights granted are temporary or permanent. [PLR 202551041]

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