Tax Cuts and Jobs Act: Interim Guidance on UBTI Siloing Rules

August 23, 2018

On August 21, 2018, the IRS issued Notice 2018-67, which includes a request for comments with interim guidance regarding how to apply the new unrelated business taxable income (UBTI) “siloing” rules of section 512(a)(6) of the Code. That section, added as part of the Tax Cuts and Jobs Act of 2017, generally provided that tax-exempt organizations can no longer aggregate income and deductions from different trades or businesses. For example, a university that both provides public parking services and rents out space for conferences can no longer use losses or deductions from one of those activities to offset unrelated business taxable income from the other.

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