ARTICLE
24 November 2020

IRS Finalizes UBTI Regulations

CW
Cadwalader, Wickersham & Taft LLP

Contributor

Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
On November 19, 2020, Treasury and the IRS issued final regulations under section 512(a)(6) of the tax code.
United States Tax

On November 19, 2020, Treasury and the IRS issued final regulations under section 512(a)(6) of the tax code. Under that section, a tax-exempt organization with more than one unrelated trade or business must compute UBTI separately with respect to each business, and cannot offset income from one business with losses from another.  

The final regulations largely follow the proposed regulations issued in April 2020, which we discussed here.  

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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