News & Resources

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

Brad Bedingfield

8/23/2018

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.

To read the full advisory, please click here:
Interim Guidance on UBTI Siloing Rules

X
Disclaimer

Communications Policy for Hemenway & Barnes

Thank you for your interest in Hemenway & Barnes, but merely communicating with Hemenway & Barnes LLP or a Hemenway & Barnes lawyer or employee will not create a lawyer-client relationship. Such a relationship will not arise unless and until the firm agrees with you in writing to handle a particular matter. Unless and until this has occurred, you should not convey to us any information you regard as personal or confidential, because any such information will not be treated by us as confidential or subject to any confidentiality requirements.

Our website offers several opportunities for visitors to request information. We use this contact information to send users information about our firm and their selected areas of interest. We may not be able to respond to your request for a variety of reasons, but appreciate your interest in our firm.