Where Is the Line Between Adjusted Revenue and Income?

The Internal Revenue Service (IRS) recently shared its view on this question with taxpayers and the real estate investment trust (REIT) industry in the context of percentage leases. On February 4, 2022, the IRS released Private Letter Ruling 202205001 and reminded taxpayers that names do not matter; calling something "revenue" does not disguise the fact that it may be subject to recast by the IRS as "income" for tax purposes.

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