New IRS Revenue Ruling Raises Concerns for Pension Funds
By 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.