State Tax Treatment of UBTI for Exempt Organizations: Calculations, Conformance, and Apportionment
A live 110-minute CPE video webinar with interactive 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

Julia Flannery
Tax Senior Manager
RSM US
Ms. Flannery is a Tax Senior Manager at RSM US.
| Read MoreMs. Flannery is a Tax Senior Manager at RSM US.
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Nancy Ortmeyer Kuhn
Shareholder
Shulman Rogers
Ms. Kuhn has a strong and diverse background in tax planning, tax policy, representation of taxpayers before the... | Read More
Ms. Kuhn has a strong and diverse background in tax planning, tax policy, representation of taxpayers before the IRS and general litigation. She supports clients including domestic and foreign high net-worth individuals, corporations, nonprofit organizations, and domestic and foreign limited liability entities in a variety of federal and state tax and non-tax matters and litigation in federal and state courts.
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Patrick Lawler
Senior Manager, State and Local Tax
RSM US
Mr. Lawler is a Senior Manager, State and Local Tax at RSM US LLP.
| Read MoreMr. Lawler is a Senior Manager, State and Local Tax at RSM US LLP.
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CPE processing must be ordered prior to the event.
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Early Discount (through 06/13/25)
CPE credit is not available on downloads.
CPE On-Demand