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.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
