REIT principally invests in U.S. energy infrastructure assets and intends to acquire an offshore oil and gas platform, storage tank facilities (including include various interests in or rights to occupy land, driveways, roadways, docks, rail spurs, dikes, fencing, loading/unloading facilities, and storage tanks), and pipelines. The IRS holds that rent paid by the platform lessee; the fees paid by users of the storage tank facilities; and fees paid by pipeline users qualify as rents from real property