CNSREIT-AR-2024 Final - Flipbook - Page 88
However, stockholders that are tax-exempt, such as charities or qualified pension plans, would have no benefit from
their deemed payment of such tax liability unless they file U.S. federal income tax returns and thereon seek a refund of
such tax. We also may be subject to state and local taxes on our income or property, including franchise, payroll, mortgage
recording and transfer taxes, either directly or at the level of the other companies through which we indirectly own our
assets, such as our taxable REIT subsidiaries, which are subject to full U.S. federal, state, local and foreign corporate-level
income taxes. Any taxes we pay directly or indirectly will reduce our cash available for distribution to you.
Restrictions on deduction of our interest expense could prevent us from satisfying the REIT distribution requirements
and avoiding incurring income or excise taxes.
Rules enacted as part of the Tax Cuts and Jobs Act may limit our ability (and the ability of entities that are not treated
as disregarded entities for U.S. federal income tax purposes and in which we hold an interest) to deduct interest expense.
The deduction for business interest expense may be limited to the amount of the taxpayer9s business interest income plus
30% of the taxpayer9s
