IRS Publishes Final Regulations Regarding UBTI “Silos”
As described in our previous blog post, Code § 512(a)(6), which was enacted in 2017 as part of the Tax Cuts and Jobs Act (the “Act”), provides that, in the case of an organization with more than one unrelated trade or business, unrelated business taxable income (“UBTI”) shall be computed separately with respect to each such trade or business. Internal Revenue Code (“Code”) § 513(a) defines “unrelated trade or business” to mean any trade…