By:  Amanda Wilson

The IRS has released yet another private letter ruling (Letter 201522002) in the REIT area.  This time, the IRS addressed the REIT treatment of income from the rental of outdoor advertising space (i.e., billboards).  At issue were outdoor advertising displays which allowed for multiple advertising copy to be shown on the same display, with the copy for the various advertisers rotating every few seconds.

The IRS held that the income derived from renting this advertising space constituted rents from real property and thus was good REIT income.