Passthrough investments by exempt organizations.
| Jurisdiction | United States |
| Author | Dally, Curtis L. |
| Date | 01 May 1997 |
Tax-exempt organizations must exercise care when investing in partnerships or S corporations. These investments can subject the organization to tax on its unrelated business taxable income (UBTI) on some or all of the passthrough income.
Sec. 512(c)(1) provides:
If a trade or business regularly carried on by a partnership of which an organization is a member is an unrelated trade or business with respect to such organization, such organization in computing its unrelated business taxable income shall, subject to the exceptions, additions, and limitations contained in subsection (b), include its share (whether or not distributed) of the gross income of the partnership from such unrelated trade or business and its...
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