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2000-03

Type
PLR
Subject
2.01a - Rents from Real Property - 75% Income Test - Generally
2.01b - Rents from Real Property - 75% Income Test - Permissible Services
2.02 - Interest
2.08a - Generally
4.04 - Third Party Service Subsidiary (Preferred Stock Subsidiary)
Keywords
Billboard Rentals
Common Area Maintenance
Cleaning Public Entrances, Exits, Stairways, Walkways, Lobbies, Restrooms, Snow Removal, Trash Collection, Pest Control and Painting (Each May Not Be Present in All Rulings)
E-mail Access
Executive Office Suites
Fees (Tenants and Service Providers)
Cable Services
Charge to Third-Party Provider
Non-Qualifying Income
Construction/Improvement Supervision
Qualifying Income
Lease to Third-Party Service Provider
Vending Machines
Permissible Tenant Services
Background Music
Painting of Tenant's Space
Telecommunications Services
Pest Control
Rents from Real Property
Billboard, Space for
Security Services
Generally
Guards
Telephone Service
Lease of Space to Third-Party Operators
Third-Party Service Subsidiary
Construction Fees
Development Fees
Executive Office Services to Tenants
Management Fees
Utilities
Generally (Electric, Gas, Water, Sewer)
Vending Machines
Space Provided to Third Parties
Year
2000
IRS Link
http://www.irs.gov/pub/irs-wd/9952084.pdf
Summary

A REIT's operating partnership or its third party subsidiary can provide a variety of services without disqualifying otherwise qualifying income from being "rents from real property."

Title
199952084
Guidance Tags
PLR - 199952084
Referenced By
N/A