United States:
IRS Finalizes UBTI Regulations
24 November 2020
Cadwalader, Wickersham & Taft LLP
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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.
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