IRS Finalizes UBTI Regulations

On November 19, 2020, Treasury and the IRS issued final regulations under section 512(a)(6) of the tax code. Under that section, a tax-exempt organization with more than one unrelated trade or business must compute UBTI separately with respect to each business, and cannot offset income from one business with losses from another.  

The final regulations largely follow the proposed regulations issued in April 2020, which we discussed here.  

 

Key Contacts

 
 
 
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