NADA announced this morning that the Internal Revenue Service has released guidance addressing the tax treatment of payments that dealerships receive from manufacturers pursuant to facility image programs with three different sets of features.  In the guidance, the IRS Office of Chief Counsel concludes that the manufacturer payments under each of the three programs must be included in the dealership’s gross income.  Dealers who receive manufacturer facility image program payments should consult with their tax advisor concerning this guidance.  Click HERE for a copy of the guidance.  This memo and its contents should not be construed as tax and/or legal advice.