CHA News Article

IRS Requests Comments on Unrelated Business Income Calculation
Provides guidance for exempt organizations

Last month, the Internal Revenue Service (IRS) issued Notice 2018-67, which requests public feedback on the calculation of unrelated business taxable income. The notice also provides interim guidance and transition rules related to IRS Code Section 512(a)(6) for exempt organizations with more than one unrelated trade or business. Finally, the notice addresses treatment of Global Intangible Low-Taxed Income Inclusions (GILTI) for purposes of unrelated business income (UBI).

Exempt organizations may rely on the notice for tax years beginning after Dec. 31, 2017, until proposed regulations are published. Organizations may rely on reasonable, good-faith interpretations of the unrelated business income rules, taking into account all the facts and circumstances.

 Comments are due Dec. 3.