Final Regulations on “Grouping” Unrelated Trades or Businesses for Purposes of UBTI Calculation
Author: Katherine E. David, J.D..
Source: Volume 20, Number 01, November/December 2020 , pp.8-11(4)
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Abstract:
The IRS has issued final regulations that provide guidance on how an exempt organization subject to the unrelated business income tax under IRC §511 determines if it has more than one unrelated trade or business, and, if so, how it calculates unrelated business taxable income (UBTI). The final regulations follow proposed regulations issued in August 2020, with some modifications. This article highlights key provisions of the final regulations and certain differences between the proposed and final regulations.Keywords: IRC §512(a)(6); UBTI; Grouping by NAICS Code; Allocating Deductions; Aggregating Investment Activities
Affiliations:
1: Clark Hill PLC.