November 19, 2020
IRS issues final regulations on how an exempt organization determines if it has more than one unrelated trade or business and how to calculate UBTI
The IRS has issued final regulations (TD 9933) with guidance on how an exempt organization determines if it has more than one unrelated trade or business and, if it has more than one, how to calculate unrelated business taxable income (UBTI). The final regulations clarify that the "unrelated trade or business" definition applies to individual retirement accounts and that inclusions of subpart F income and global intangible low-taxed income (GILTI) are treated like dividends in determining UBTI. A Tax Alert is forthcoming.