IRS Releases Interim and Transition Rules Regarding the Calculation of Unrelated Business Taxable Income Under Code Section 512(a)(6)
On August 21, 2018, the IRS released Notice 2018-67 (the “Notice”). The Notice provides interim and transition rules for the calculation of unrelated business taxable income (“UBTI”) under new section 512(a)(6) of the Internal Revenue Code of 1986, as amended, which requires that a tax-exempt organization with more than one unrelated trade or business calculate UBTI separately with respect to each unrelated trade or business.