Looks count – IRS wants “image money” included in a dealership’s gross income

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Abstract: One way that some automobile manufacturers motivate dealerships to renovate, modernize and upgrade their facilities is by encouraging them to participate in “facility image upgrade programs.” These programs often provide payments to dealerships to help defray costs. Some dealerships wonder how these payments — referred to by the IRS as “upgrade image support” payments and commonly called “image money” by dealers — should be treated from a tax perspective. This article discusses a recent IRS General Legal Advice memorandum clarifying its position on this issue.