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2001-14

Type
PLR
Subject
2.01a - Rents from Real Property - 75% Income Test - Generally
2.01b - Rents from Real Property - 75% Income Test - Permissible Services
2.07 - Non-Qualifying Income
4.01b - Government Securities and Cash or Cash Equivalents
Keywords
Gross Income
Defined
Naming Rights
Impermissible Services
Impact on Rents
Rents Not Affected
Naming Rights
Permissible Tenant Services
Naming Rights
Ruling by Property Type
Retail
Retail Property Service Rulings
Year
2001
IRS Link
http://www.irs.gov/pub/irs-wd/0140026.pdf
Summary

Income attributable to naming rights granted by a REIT's subsidiary partnership to a third party is not itself qualifying income but will not taint otherwise qualifying rental income.

Title
200140026
Guidance Tags
PLR - 200140026
Referenced By
N/A