The first article in this series (March 2009) examined the issues involved when a tax-exempt organization leases improved property to one or more parties. The primary issue examined in that
Tax Issues for Real Estate Leasing By Tax-Exempt Organizations
In private rulings, the IRS has sanctioned several ways in which a prime lease to a tenant that subleases to others can structure a gross receipts formula for rent that will not result in the rental payments being characterized as based in whole or in part on profits.
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