The IRS has determined that the rental of parking spaces or lots which are not operated by a third-party contractor are not considered rents from real property, regardless of whether any services are provided.
Income generated by the operation of parking lots and parking garages for the use of students, faculty, staff, vendors, affiliated organizations and others on premises for official University business or to participate in University programs is not subject to unrelated business income tax (UBIT) as they are necessary for the normal conduct of the University mission.
Long-term contractual arrangements for the lease or rental of parking spaces, such as the agreement with the Marriott Hotel, are subject to UBIT.