benefit of the refugees.27 The UN has a duty of care in managing these properties, and any revenues derived from them (e.g. rents, agricultural use, or other income-generating activities) should legally be held in trust and directed toward the benefit of the refugees themselves.28 These revenues could partially fund services provided by UNRWA, consistent with the UN’s fiduciary responsibilities. The UNGA’s Resolution 36/146C of 1981,29 recognizes refugees’ rights to both their properties and the income generated from them. It calls on the UNSG, in consultation with the UNCCP, to take steps to protect these assets and to establish a fund to receive the revenues. If fully activated and implemented, though continuously prevented from doing so by the Israeli regime since 1949,30 a UN-administered fund could ensure that the income from refugee properties is directed toward supporting Palestinian refugees—including through partially financing UNRWA’s essential services—until restitution and return are fulfilled.31 These are but two alternative financing pathways that could be 27 BADIL Resource Center for Palestinian Residency and Refugee Rights. Forced Population Transfer: The Case of Palestine – Denial of Reparations, Working Paper No. 22. Bethlehem: BADIL, October 2018. https://badil.org/cached_uploads/view/2021/04/19/wp22-reparations-ofreparations-1618823911.pdf. 28 United Nations Conciliation Commission for Palestine. Measures for the Protection of the Rights, Property and Interests of the Palestine Arab Refugees. UN Doc. A/AC.25/W/81/Rev.2. New York: United Nations, (11 March 1964). https://www.un.org/unispal/document/autoinsert-179612/. 29 United Nations General Assembly, Resolution 36/146C: Palestine Refugees’ Properties and Their Revenues, A/RES/36/146C (December 9, 1981). https://documents.un.org/doc/resolution/ gen/nr0/407/72/pdf/nr040772.pdf. 30 Adnan Abdelrazek, “Israeli Violation of UN Resolution 194 (III) and Others Pertaining to Palestinian Refugee Property,” Palestine-Israel Journal 15–16, no. 3 (2008), https://pij.org/ articles/1220; United Nations General Assembly, Report of the Secretary-General on Palestine Refugees’ Properties and Their Revenues, A/72/334 (August 14, 2017). https://docs.un.org/ en/A/72/334. 31 BADIL Resource Center for Palestinian Residency and Refugee Rights. Forced Population Transfer: The Case of Palestine – Denial of Reparations, Working Paper No. 22. Bethlehem: BADIL, October 2018. https://badil.org/cached_uploads/view/2021/04/19/wp22-reparations-ofreparations-1618823911.pdf. 12