Exhibit 8.1

	DLA Piper LLP (US) 444 West Lake Street, Suite 900 Chicago, Illinois 60606-0089 www.dlapiper.com
	T 312.368.4000 F 312.236.7516

April 25, 2022

Corporate Property Associates 18 – Global Incorporated

One Manhattan West

395 9th Avenue, 58th Floor

New York, New York 10001

Re:     Tax Opinion for REIT Status

Ladies and Gentlemen:

We have acted as counsel to W. P. Carey Inc., a Maryland corporation (the “Company”) in connection with the Agreement and Plan of Merger dated as of February 27, 2022, by and among Corporate Property Associates 18 – Global Incorporated, a Maryland corporation (“CPA18”), the Company, CPA18 Merger Sub LLC, a Maryland limited liability company (“Merger Sub”) and an indirect subsidiary of the Company, and, for the limited purposes set forth therein, Carey Asset Management Corp., a Delaware corporation, W. P. Carey & Co. B.V., a private company with limited liability (besloten vennootschap met beperkte aansprakelijkheid) incorporated under the Laws of the Netherlands, and WPC-CPA:18 Holdings, LLC, a Delaware limited liability company, each an indirect subsidiary of the Company, and CPA®:18 Limited Partnership, a Delaware limited partnership (the “Merger Agreement”). Pursuant to the Merger Agreement, CPA18 will merge with and into Merger Sub, with Merger Sub surviving as a direct subsidiary of WPC Holdco LLC, a Maryland limited liability company, and direct subsidiary of the Company.

Pursuant to 5.3(e) of the Merger Agreement, CPA18 is to receive an opinion (the “Opinion”) as to whether, commencing with the Company’s taxable year ended December 31, 2018, the Company has been organized and operated in conformity with the requirements for qualification and taxation as a real estate investment trust (“REIT”) under Section 856 of the Internal Revenue Code of 1986, as amended (the “Code”), and its current and proposed method of operation as described in the registration statement on Form S-4, File No. 333-264120, including the proxy statement/prospectus contained therein at the time the registration statement is declared effective (the "Proxy Statement/Prospectus"), filed by the Company with the Securities and Exchange Commission (the "Commission") under the Securities Act of 1933, as amended (the "Act") on April 4, 2022 (as amended through the date hereof, excluding the documents incorporated by reference therein, the "Registration Statement") will enable the Company to continue to meet the requirements for qualification and taxation as a REIT under the Code.

In connection with rendering the Opinion, we have examined originals (or copies identified to our satisfaction as true copies of the originals) of the following documents (collectively, the “Reviewed Documents”):

(1)the Company’s Articles of Amendment and Restatement in effect as of the date hereof (the “Articles”);

(2)the Company’s Fifth Amended and Restated Bylaws in effect as of the date hereof (the “Bylaws”);

(3)the Registration Statement;

(4)the Proxy Statement/Prospectus;

Page 2

(5)the Merger Agreement; and

(6)such other documents as may have been presented to us by the Company from time to time.

In addition, we have relied upon the factual representations contained in the certificate issued by the Company, dated as of the date hereof, executed by a duly appointed officer of the Company, setting forth certain representations relating to the organization and proposed operation of the Company and its subsidiaries (the “Certificate”).

For purposes of our Opinion, we have not made an independent investigation of all of the facts set forth in the documents we reviewed. We consequently have assumed that the information presented in such documents or otherwise furnished to us accurately and completely describes all material facts relevant to our Opinion. No facts have come to our attention, however, that would cause us to question the accuracy and completeness of such facts or documents. Any representation or statement in any document upon which we rely that is made “to the best of our knowledge” or otherwise similarly qualified is assumed to be correct. Any alteration of such facts may adversely affect our Opinion.

In our review, we have assumed, with the consent of the Company, that all of the representations and statements of a factual nature set forth in the documents we reviewed are true and correct, and all of the obligations imposed by any such documents on the parties thereto have been and will be performed or satisfied in accordance with their terms. We have also assumed the genuineness of all signatures, the proper execution of all documents, the authenticity of all documents submitted to us as originals, the conformity to originals of documents submitted to us as copies, and the authenticity of the originals from which any copies were made.

The Opinion set forth in this letter is based on relevant provisions of the Code, the regulations promulgated thereunder by the United States Department of the Treasury (“Regulations”) (including proposed and temporary Regulations), and interpretations of the foregoing as expressed in court decisions, the legislative history, and existing administrative rulings and practices of the Internal Revenue Service (“IRS”), including its practices and policies in issuing private letter rulings, which are not binding on the IRS except with respect to a taxpayer that receives such a ruling, all as of the date hereof.

In rendering this Opinion, we have assumed that the transactions contemplated by the Reviewed Documents have been or will be consummated in accordance with the terms and provisions of such documents, and that such documents accurately reflect the material facts of such transactions. In addition, the Opinion is based on the assumption that the Company and its subsidiaries will each be operated in the manner described in the Articles, the Bylaws and the other organizational documents of each such entity and their subsidiaries, as the case may be, and all terms and provisions of such agreements and documents will be complied with by all parties thereto.

It should be noted that statutes, regulations, judicial decisions and administrative interpretations are subject to change at any time and, in some circumstances, with retroactive effect. A material change that is made after the date hereof in any of the foregoing bases for our Opinion could affect our conclusions. Furthermore, if the facts vary from those relied upon (including if any representations, warranties, covenants or assumptions upon which we have relied are inaccurate, incomplete, breached or ineffective), our Opinion contained herein could be inapplicable. Moreover, the qualification and taxation of the Company as a REIT depends upon its ability to meet, through actual annual operating results, distribution levels and diversity of share ownership and the various qualification tests imposed under the

2

Page 3

Code, the results of which will not be reviewed by the undersigned. Accordingly, no assurance can be given that the actual results of the operations of the Company for any one taxable year will satisfy such requirements.

Based upon and subject to the foregoing, we are of the opinion that commencing with its taxable year ended December 31, 2018, the Company has been organized and operated in conformity with the requirements for qualification and taxation as a REIT under the Code, and its current and proposed method of operation as described in the Registration Statement and the Proxy Statement/Prospectus contained therein will enable the Company to continue to meet the requirements for qualification and taxation as a REIT under the Code.

The foregoing Opinion is limited to the matters specifically discussed herein, which are the only matters to which the Company has requested our opinion pursuant to the Merger Agreement. Other than as expressly stated above, we express no opinion on any issue relating to the Company or to any investment therein

This letter is being provided to CPA18 at the request of the Company in connection with the Merger Agreement. Only CPA18 may rely on this letter. Without our prior written consent, this letter may not be relied upon by any other person or entity or used for any other purpose. We assume no obligation to advise CPA18 or the Company of any changes in the foregoing subsequent to the date of this letter, and we are not undertaking to update this letter from time to time. Please note that an opinion of counsel represents only counsel’s best legal judgment, and has no binding effect or official status of any kind, and that no assurance can be given that contrary positions may not be taken by the IRS or that a court considering the issues would not hold otherwise.

We consent to the filing of this Opinion with the Commission as an exhibit to the Registration Statement and to the references to our firm in the final Proxy Statement/Prospectus included in the Registration Statement. In giving this consent, we do not thereby admit that we are within the category of persons whose consent is required under Section 7 of the Act or the rules and regulations of the Commission promulgated thereunder.

Very truly yours,

/s/ DLA Piper LLP (US)

DLA Piper LLP (US)

3