Daily Tax Report ®

IRS Prop. Reg.: Comments Submitted on Unrelated Business Taxable Income (IRC §511)

June 30, 2020, 5:00 AM

Public comments released June 30 on REG-106864-18 that would determine if an exempt organization has more than one unrelated trade or business, and, if so, how it calculates unrelated business taxable income. The comments focus on the appropriateness of using two-digit NAICS sector codes to group unrelated trades or businesses, which would allow, for example, a non-profit organization to offset its profits from an oil well with losses from a coal mine (both under NAICS sector code 21 for mining, quarrying, and oil and gas extraction businesses) or to combine taxis and natural gas pipelines (under NAICS sector code 48...

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