IRS Pushes Back on Expanded Definition of “Educational Organization”
Author: Katherine E. David, J.D..
Source: Volume 19, Number 02, January/February 2020 , pp.12-12(1)
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Abstract:
In August 2019, a Michigan federal district court ruled that the Mayo Clinic is entitled to an $11.5 million refund of unrelated business taxable income (UBTI) because it qualifies as an “educational organization” under IRC §170(b)(1)(A)(ii). At issue was whether Mayo Clinic qualified for an exception to the rule that income from debt-financed property constitutes UBTI that is available to organizations described in IRC §170(b)(1)(A)(ii).Keywords: Definitions of “Educational Organization”; IRC §514(c)(9)(C)(i); Mayo Clinic
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1: Clark Hill PLC.