The tax treatment of entrance and monthly fees paid to continuing care retirement communities (CCRCs) has developed over time through the issuance of several public and private Internal Revenue Service (IRS) rulings and a few seminal decisions by the courts. CCRCs have relied on these rulings and decisions in structuring and funding their operations. This article reviews IRS guidance and judicial precedent on the subject, from the earliest rulings and cases to the IRS’s most recent administrative practice and litigating position.
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