Unrelated Business Income

How much unrelated business activity is too much?

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.

Sorting out tax exempts’ UBTI painlessly

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.

Prop. Regs. Ease UBTI Consequences for CRTs

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.

Debt-Financed Income and 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

Teaching an Old Dog New Tricks: CRTs and UBTI

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

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TAX RELIEF

Quirks spurred by COVID-19 tax relief

This article discusses some procedural and administrative quirks that have emerged with the new tax legislative, regulatory, and procedural guidance related to COVID-19.