Copper Property

CTL Pass Through Trust

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Copper Property CTL Pass Through Trust (the “Trust”) is a New York common law trust. The Trust was established to acquire 160 retail properties and 6 warehouse distribution centers (collectively the “Properties”) from J.C. Penney as part of its Chapter 11 plan of reorganization (the “Plan of Reorganization”) and to sell all of its assets. The Trust is intended to be treated, for tax purposes, as a liquidating trust within the meaning of United States Treasury Regulation Section 301.7701-4(d).

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