UBIT Silos: Proposed Regulations

On April 24, 2020, the IRS and Treasury Department published proposed regulations under the law commonly referred to as the Tax Cuts and Jobs Act (TCJA) that provide guidance on how a tax-exempt organization subject to unrelated business income tax (UBIT) determines if it has more than one unrelated trade or business, and, if it […]

IRS Guidance on UBIT Silos – 512(a)(6) – PART II

In Part I of this two-part article on IRS Notice 2018-67 regarding the calculation of unrelated business taxable income (UBTI) under the Tax Cuts and Jobs Act (TCJA), we discussed the need to separate different lines of unrelated business activities, which is now required to calculate an organization’s unrelated business income tax (UBIT). In Part II, we focus on special […]

UBIT – Issues for Shared Spaces

  I will be speaking this week for The Nonprofit Centers Network on unrelated business income tax (“UBIT”) related issues faced by nonprofits providing shared space with other individuals or entities (you can register for the webinar here).  As we’ve discussed in previous posts on UBIT, generally, net income from unrelated business activities will be […]

Unrelated Business Income Tax Explained

In order to qualify as a tax-exempt organization under IRC Section 501(c)(3), an organization must be operated primarily for tax-exempt purposes. This parameter allows such nonprofit organizations to engage in a limited amount of business activity unrelated to the organization’s exempt purposes. Although a public charity generally does not pay taxes on income from activities […]

Earned Income 101 for Nonprofits – Webinar

Earlier today, Emily and I presented Earned Income 101 for Nonprofits for Nonprofit Webinars.  You'll find our PowerPoint presentation on the site.  I've reproduced the introduction here: Many nonprofits use earned income as a source of revenue generation. For example, it was estimated in 2008 that nearly 70% of the $1.4 trillion generated by nonprofits came from […]

Nonprofit Radio: Earned Income & Unrelated Business Income Tax

This month on Tony Martignetti Nonprofit Radio, Emily and I discussed with Tony the topics of earned income and the unrelated business income tax.  You can listen to a recorded version here or check it out (in a few days) on ITunes. Frequently Asked Questions Note:  To provide a more easily understandable overview, we answered these in general terms […]