Examine unrelated business income tax (UBIT) and related issues. Review changes made by The Tax Cuts and Jobs Act, along with any interim and final guidance on those changes and the special UBIT rules and their application to particular organizations and entities. Understand the impacts of the CARES Act and American Recovery Plan on the UBIT on income earned from both operating businesses and investment activities applies to all organizations exempt from tax under Internal Revenue Code Sec. 501(c), as well as public colleges and universities and qualified and non-qualified retirement plans. Explore tax and related issues. Also, examine modifications, exclusions, exceptions and deductible expenses. Further, discuss the specific deduction and special rules for debt-financed income, corporate sponsorships and periodicals, and gaming activities. Receive tips for clients regarding the structuring of new revenue-generating activities. Dive into investment activities, which increasingly result in more organizations having unrelated business taxable income for federal and state purposes and additional filings related to foreign investments. Learn from the experience of the initial year of mandatory e-filing requirements.
Learning Objectives
• Identify the history and applications of the unrelated business income tax (UBIT)
• Learn the implications of provisions contained in The Tax Cuts and Jobs Act, as well as Final Regulations and their implications for revenue-generating activities, including operating businesses and alternative investments
• Recognize the definition of unrelated business income and its implications on both an organization's operating trades and businesses and investment activities
• Determine exclusions, modifications and exceptions to unrelated business income
• Identify debt-financed income
• Recognize the rules for deducting expenses in determining unrelated business taxable income, filing requirements, net operating loss rules, including implications of the CARES Act and the implications of earning unrelated business income beyond potentially paying tax
• Identify special rules for particular activities, including advertising, bingo and trade shows, and types of entities
• Identify federal and state filing issues
Major Topics
• Definition of unrelated business
• Unrelated business income tax: origins, exclusions, modifications and exceptions
• Tax Cuts and Jobs Act Changes and Final regulations, as well as relevant CARES Act and American Rescue Plan provisions
• Special rules for advertising, bingo and trade shows
• Debt financed income issues
• Alternative investments
• Filing requirements, including lessons learned from the past tax season
• State UBIT filings and other federal filings relating to foreign investments
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