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PLR 201944011

Type
PLR
Subject
11.01 - Generally
11.03 - Noncustomary Services
2.00 - Income Tests - (75% & 95%)
2.01b - Rents from Real Property - 75% Income Test - Permissible Services
4.01a - Real Estate Assets
Keywords
Boat Slips, Marina
Interest in Real Property
Lodging Facilities
Eligible Independent Contractor
Permissible Tenant Services
Real Estate Asset
Steel Racking Structures
Storage Facility Services
Taxable REIT Subsidiary
Noncustomary Services, Paid for by Tenant
Operation of Lodging Facility
Rents from Real Property
Year
2019
IRS Link
https://www.irs.gov/pub/irs-wd/201944011.pdf
Tax Report Link
Review of 2019 REIT-Related Private Letter Rulings
Summary

Rental income from boat slips and storage spaces at a marina constitutes rents from real property, and 2) the income from the services provided at the marina is not impermissible tenant service income and, therefore, will not cause any portion of the rents receive from the tenants of marina to fail to qualify as rents from real property.

Title
PLR 201944011