State Tax Treatment of UBTI for Exempt Organizations: Calculations, Conformance, and Apportionment
Navigating States' Partial- or Non-Conformance With Federal Treatment; Multistate Apportionment Rules
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE video webinar with Q&A
This course will provide nonprofit tax professionals and advisers with a practical guide to various states' rules governing unrelated business income tax, which U.S.-based tax-exempt organizations must pay on unrelated business taxable income (UBTI). The webinar will focus on the standards and guidelines for determining whether income is UBTI and thus subject to tax, identify those states that deviate from federal treatment, and list those states whose definitions conform to federal rules but have different calculation bases.
Outline
- Federal treatment of UBTI
- Identifying UBTI
- UBTI calculations and schedules
- Tax computation
- Allocation of expense deductions
- State treatment of UBTI
- States not conforming with federal exempt org classification
- States that tax UBTI
- Common states' adjustments to federal UBTI calculations
- Range of rules for NOL carry-backs and carry-forwards
- Apportionment challenges
- Pass-through considerations
- Section 512(a)(6) Siloing unrelated trade and businesses
Benefits
The panel will discuss these and other important topics:
- What states deviate from federal treatment of UBTI?
- What states generally conform to federal UBTI calculations but with add-backs?
- State deviations in NOL carry-back and carry-forward treatment for UBTI
- Which states require a different formula for apportioning UBTI than the one applicable to for-profit commercial entities?
Faculty
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Nancy Ortmeyer Kuhn
Director
Jackson & Campbell
Ms. Kuhn specializes in Federal and state tax matters and is the Chair of the firm's Tax Group. She has... | Read More
Ms. Kuhn specializes in Federal and state tax matters and is the Chair of the firm's Tax Group. She has a strong and diverse background in tax planning, representation of taxpayers before the IRS, and tax litigation. She advises clients with complex non-profit/for-profit structures including joint ventures, affiliated 501(c)(3)/501(c)(4)/527 entities, micro-finance non-profit/for-profit affiliations, supporting organizations, and domestic/international affiliated non-profit/for-profit entities. She also assists clients in navigating and negotiating favorable settlements in employment tax and individual collection matters. She represents clients with unrelated business taxable income planning, compliance, and IRS examination issues and also advises individuals with regard to foreign and domestic tax issues.
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