New Guidance on Calculating UBTI for Separate Trades or Businesses Under Tax Reform
What Constitutes Unrelated Separate Lines of Businesses, Using Silos to Compute UBTI, Anti-Netting Provisions
A live 110-minute CPE webinar with interactive Q&A
This webinar will provide tax advisers and exempt org personnel with a critical first look at the new IRS guidance on identifying separate lines of trade or businesses for purposes of calculating unrelated business taxable income (UBTI) as is now required by the TCJA tax reform law. The panel will detail the specifics of siloing separate lines of business, describe the impact of new rules governing net operating loss carryforwards, and discuss how to apply the new guidance in calculating UBTI and its required tax. The webinar assumes the attendee is already at least conversant with the standards and guidelines for determining whether income is UBTI and thus subject to tax.
- Section 512(a)(6) provisions
- Proposed regs concepts on identifying separate and unrelated lines of business using NAICS codes
- “Siloing” to comply with prohibitions against netting losses and income from unrelated trades held by nonprofits
- Permissible aggregation
- Transitional safe harbors
- Items open for practitioner comment
The panel will discuss these and other high priority topics:
- Using NAICS codes to identify separate, unrelated trades or businesses
- What the Notice says about the Service’s thoughts on the treatment of partnership income, and of income derived from passive investments
- What safe harbor may exempt org advisers and compliance professionals use to avoid additional tax and penalties?
William M. Funk
Law Office of William M. Funk
Mr. Funk focuses his practice on tax law, with extensive experience in tax planning and dispute work. He... | Read More
Mr. Funk focuses his practice on tax law, with extensive experience in tax planning and dispute work. He represents individuals, businesses, funds and non-profit organizations. He successfully represents clients before federal and state tax authorities and in business negotiations. He counsels clients regarding structuring investments and developments by nonprofits to avoid exposure to unrelated business income tax. He has also been published in leading tax publications on a wide array of tax issues ranging from taxation of real estate developments to international tax policy.Close
Elizabeth M. Mills
Elizabeth M. Mills
Ms. Mills’ practice is focused both on healthcare organizations and tax exemption issues for not-for-profit... | Read More
Ms. Mills’ practice is focused both on healthcare organizations and tax exemption issues for not-for-profit organizations. She addresses regulatory and transactional issues for all types of health care providers and advises as changes to their particular tax exemption standards are proposed, implemented and litigated. In addition, Ms. Mills assists tax-exempt organizations in addressing tax compliance and governance issues and represents organizations being audited by the IRS, new organizations obtaining tax exemption from the IRS, and existing organizations addressing changes in their activities or structure. She speaks and writes frequently on tax exemption matters, particularly for health organizations.Close
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