Unrelated Business Income
This item discusses the IRS position allowing the unrelated activities to be substantial so long as they are not the organization’s “primary purpose,” while also acknowledging the confusion and uncertainty on this point.
To help exempt organizations “silo,” or separately compute, their unrelated business or trade income, three experts who will be giving a presentation on the topic at the upcoming Not-for-Profit Industry Conference offer their thoughts.
IRS regulations discuss how an exempt organization calculates unrelated business taxable income if it has more than one unrelated trade or business.
The IRS has posted final regulations governing how tax-exempt organizations determine if they have more than one unrelated trade or business for purposes of unrelated business income tax.
The article discusses the June 2020 proposed regulations and how they compare to the prior guidance in Notice 2018-99.
The IRS issued guidance outlining how to determine the amount of parking expense that is nondeductible under Sec. 274(a)(4) when employers provide parking for their employees.
The IRS issued guidance outlining how to determine the amount of parking expense that is nondeductible under Sec. 274(a)(4) when employers provide parking for their employees.
Notice 2018-67 provides interim and transition rules for aggregating qualifying partnership interests.
Proposed regulations could present tax-saving opportunities for qualified organizations that invest in partnerships.
This item details some charitable giving options for owners of closely held businesses, the applicable unrelated business income and self-dealing rules, and best practices for taxpayers who have these charitable desires and restrictions.
How an exempt organization computes UBTI for state income tax purposes varies from state to state.
Determining whether receipts qualify as sponsorship payments or advertising income can be quite burdensome for most nonprofit organizations. The item describes how to properly structure unrelated business taxable income so as not to adversely affect the organization’s cashflow.
This item provides an overview of some areas of taxation that taxpayers and their advisers must consider to ensure the most favorable terms if their clients are approached by an energy company seeking a land lease and royalty agreement.
The Service has issued proposed regulations to reflect the change made by TRAHCA to impose a 100% excise tax on the unrelated business taxable income (UBTI) of charitable remainder trusts (CRTs) that have UBTI.
Editor: Joel E. Ackerman, CPA, MST Two exempt organizations meet the requirements of Sec. 501(c)(3) (one as a charitable organization and the other as an educational organization—a university). These organizations own equal interests in a partnership, and they have boards of trustees that overlap by more than 50% of the
Dec. 20, 2006 marked a unique day in the taxation of charitable remainder trusts (CRTs)— President Bush signed into law the Tax Relief and Health Care Act of 2006 (TRAHCA ’06). Buried in that legislation is revised Sec. 664(c), which significantly alters the tax treatment of unrelated business taxable income
