Tax insight

REIT PLR addresses EV charging stations, amenities, storage facility services

Insight
5 minute read
December 12, 2025

What happened?

In Private Letter Ruling (PLR) 202530005, the IRS addressed a number of issues for a REIT that provided storage for equipment that relate to:

electric vehicle charging stations for the equipment;
charging mark-ups on the electricity provided by the charging stations;
use of an amount of space without a specific designation of space;
amenities such as portable restrooms, showers, and weigh stations;
cleaning, utilities, and basic maintenance; and
leases to taxable REIT subsidiaries of the amenities.

Why is it relevant?

The PLR offers guidance to REITs that lease storage facilities with enhanced services to tenants, including electricity provided through electric vehicle (EV) stations, without jeopardizing the qualification of rental income earned by REITs under the REIT income tests. This PLR also demonstrates the importance of providing enhanced services through taxable REIT subsidiaries (TRSs) and independent contractors (IKs) where necessary to manage a REIT’s impermissible tenant services income (ITSI) limit for purposes of the REIT gross income tests.

Action items to consider

REITs operating storage or industrial properties may want to evaluate the analysis in the PLR or consider obtaining their own ruling to determine the REIT qualification of the services provided directly at their storage or industrial properties.