Flow Charts for Implementing UBTI Siloing Rules

Posted May 26th, 2021 & filed under Blog.

This article has been updated to reflect the latest guidance as of 5/26/2021. It was originally published on 6/1/2020. 

On December 2, 2020, the IRS published final regulations on the unrelated business taxable income (UBTI) siloing rules required under the Tax Act of 2017 and section 512(a)(6) of the Internal Revenue Code.

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IRS Issues Proposed Regulations on Unrelated Business Siloing

Posted August 11th, 2020 & filed under Blog.

After a long wait, the IRS finally issued proposed regulations on the unrelated business taxable income (UBTI) “siloing” rules on April 24, 2020.

These rules, under section 512(a)(6) of the Internal Revenue Code,

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The IRS Draft Form 990-T Gives UBI Clues (Updated)

Posted October 16th, 2018 & filed under Blog.

Note: This article, originally published on October 16, 2018, has been updated to include the latest developments regarding the Tax Cuts and Jobs Act. 

The IRS published a draft 2018 Form 990-T* and Instructions** for exempt organizations.

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Segregating Unrelated Trades or Businesses

Posted June 6th, 2018 & filed under Blog.

Beginning in 2018, unrelated business taxable income (UBTI) must be computed separately for each unrelated trade or business. Net operating losses (NOL) from one unrelated trade or business may not be used to offset income from another unrelated trade or business.

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