N-2018-67: Request for Comments Regarding the Calculation of Unrelated Business Taxable Income under § 512(a)(6) for Exempt Organizations with More than One Unrelated Trade or Business; Interim and Transition Rules for Aggregating Certain Income in the Nature of Investments; and the Treatment of Global Intangible Low-Taxed Income Inclusions for Purposes of the Unrelated Business Income Tax
Internal Revenue Service (IRS) sent this bulletin at 08/21/2018 11:41 AM EDT
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Issue Number: N-2018-67Inside This IssueNotice 2018-67 solicits comments regarding the application of new § 512(a)(6) of the Internal Revenue Code (“Code”), which was added to the Code by section 13702 of “An Act to provide for reconciliation pursuant to titles II and IV of the concurrent resolution on the budget for fiscal year 2018,” Public Law 115-97 (131 Stat. 2054 (2017)). Section 512(a)(6) requires an organization subject to the unrelated business income tax under § 511 with more than one unrelated trade or business to calculate unrelated business taxable income (“UBTI”) separately with respect to each trade or business. The notice requests comments on various topics, including possible methods for separating trades or businesses and the treatment of activities in the nature of investments and income from fringe benefits required to be included in UBTI under § 512(a)(7) for purposes of § 512(a)(6). The notice also sets forth interim and transition rules under § 512(a)(6) with respect to aggregating gross income and directly connected deductions of certain activities in the nature of investments. Notice 2018-67 will be in IRB: 2018-36, dated 9/4/2018. Thank you for subscribing to IRS GuideWire, an IRS e-mail service. If you are a Tax Professional and have a specific concern about your tax situation, call the IRS Practitioner Priority Service 1-866-860-4259. This message was distributed automatically from the IRS GuideWire mailing list. Please Do Not Reply To This Message. |