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IRS Issues Interim Guidance for “Grouping” Unrelated Trades or Businesses for Purpose of UBTI Calculation  


Author:  Katherine E. David, J.D..


Source: Volume 18, Number 01, November/December 2018 , pp.14-16(3)




Family Foundation Advisor

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Abstract: 

New IRC §512(a)(6) may increase the amount of UBTI to which an organization is subject. And, because the Tax Cuts and Jobs Act replaced the graduated corporate tax rates with a single 21% rate, organizations with small amounts of UBTI likely will see their tax bills go up as a result of the rate increase. This article examines the new IRS guidance on calculating UBTI , helps foundations prepare for the results, and alerts readers to likely regulations setting forth how separate trades or businesses are to be identified.

Keywords: Unrelated Trade or Business Income

Affiliations:  1: Clark Hill Strasburger.

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