News & Analysis as of

Internal Revenue Code (IRC) UBIT

Eversheds Sutherland (US) LLP

The One Big Beautiful Bill – sports industry sweats the over/under

As the “One Big Beautiful Bill” continues its legislative path through Congress, it remains too close to call on how the final legislation will impact the sports industry. On May 22, 2025, the House of Representatives...more

BCLP

Expanded Tax Benefits for Giving to Charity, 2020 Forms 990-T and 4720 Revisions and Other News

BCLP on

Year-end reminder: Expanded tax benefits help individuals and businesses give to charity during 2020 - The IRS today explained how expanded tax benefits can help both individuals and businesses give to charity before the...more

Troutman Pepper Locke

The Midstream REIT; New Private Letter Ruling Guidance from the IRS May Enhance REIT Investment Option for Midstream Energy Assets

Troutman Pepper Locke on

Private letter ruling 201907001 (the “PLR”), recently issued by the Internal Revenue Service (“IRS”), indicates that a midstream energy company may be able to organize as a real estate investment trust (“REIT”) under Section...more

BCLP

Form 1023 Revisions and Required Electronic Submission

BCLP on

The IRS is revising Form 1023, Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code, and its instructions, to help charities apply for 501(c)(3) tax-exempt status. Effective January...more

Morgan Lewis

IRS Instructs Nonprofits on How to Claim Parking Tax Refund

Morgan Lewis on

On December 20, 2019, Congress retroactively repealed Internal Revenue Code (IRC) Section 512(a)(7), which had increased unrelated business taxable income by amounts paid or incurred for qualified transportation fringes....more

King & Spalding

Tax-Exempt Mayo Clinic Awarded $11.5M UBIT Refund, Invalidating Treasury Regulations In the Process

King & Spalding on

In a recent taxpayer win, the United States District Court for the District of Minnesota granted summary judgment in an $11.5 million refund claim brought by the Mayo Clinic (“Mayo”) on the basis that certain Treasury...more

Eversheds Sutherland (US) LLP

Employee benefit arrangements potentially affected by revised UBIT calculations

In Notice 2018-67, released on August 21, 2018, the Internal Revenue Service (IRS) sought comments and provided interim guidance on changes in the calculation of unrelated business income tax (UBIT) enacted in the Tax Cuts...more

King & Spalding

Healthcare Highlights from the GOP’s Tax Reform Plan

King & Spalding on

The House and Senate negotiators emerged on Friday, December 15, 2017, with a compromise tax reform proposal that would overhaul the Internal Revenue Code for the first time since 1986. Nonprofit hospitals and other...more

K&L Gates LLP

Tax Cuts and Jobs Act Could have Far-reaching Effects on Higher Education

K&L Gates LLP on

The House of Representatives and the Senate are on a fast track to pass sweeping tax reform legislation that would have widespread implications for colleges and universities, their employees, and their donors. As part...more

Nossaman LLP

Might the UBIT Bite a Bit? You Bet.

Nossaman LLP on

The recent tax reform bill (Tax Cuts and Jobs Act, H.R. 1), which the House Ways and Means Committee introduced November 2, would subject public pension plans to unrelated business income tax (“UBIT”) on their pre-packaged...more

Harris Beach Murtha PLLC

Are Big Changes To The Tax Code In Store For Tax Exempt Organizations?

Deep within the 429 page Tax Cuts and Jobs Act (the "Act") reside some proposed changes that would have significant ramifications for tax exempt organizations. If the Act were to be enacted "as is" these changes would be...more

Seyfarth Shaw LLP

UBIT May Be In Your Future

Seyfarth Shaw LLP on

The proposed Tax Cuts and Jobs Act released by the House of Representatives on November 2, 2017 calls into question the position long taken by government pension plans that they are exempt from the unrelated business income...more

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