Insights
Client Alert
New IRS Revenue Ruling Raises Concerns for Pension Funds
March 24, 2004
ERISA Institutional Investment Group and Tax Advisory Practice
In an effort to identify circumstances in which a REIT’s income from the provision of parking services property, the IRS recently issued Revenue Ruling 2004-24. The Ruling indicates that the provision of parking services by a REIT generally does not generate impermissible tenant service income. However, the Ruling also indicates that the provision of these parking services will generate unrelated business taxable income for tax-exempt entities.