The University may charge a site license fee to allow cell phone companies to operate antenna facilities (cell phone towers) on University property. If the University does not own the cell phone towers, and instead only leases roof space or ground space for cell phone companies to install and maintain their cell phone towers, then the leases are real property leases and are exempt from unrelated business income tax (UBIT). On the other hand, if the University owns the cell phone towers and leases them to the cell phone companies, the leases are personal property leases and are subject to UBIT. (PLR 200104031).
