IRS Guidance on UBIT Silos – 512(a)(6) – PART II

In Part I of this two-part article on IRS Notice 2018-67 regarding the calculation of unrelated business taxable income (UBTI) under the Tax Cuts and Jobs Act (TCJA), we discussed the need to separate different lines of unrelated business activities, which is now required to calculate an organization’s unrelated business income tax (UBIT). In Part II, we focus on special issues arising from an exempt organization’s partnership investments and fringe benefits and how they are impacted by the UBIT silos described in the new law. Internal Revenue Code Section 512(a)(6) Section 512(a)(6) requires an organization subject to the unrelated business income tax under Section 511, with more than one unrelated trade or business, to calculate unrelated business taxable income (UBTI) separately with respect to each trade or business. This is required because organizations with multiple unrelated trade or business activities can no longer offset income…

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