IRS explains new UBTI rules – Clearing up the “silo rule” confusion
Abstract: Several provisions of the TCJA have significant implications for nonprofits, especially those with unrelated business taxable income (UBTI). These organizations must now calculate their UBTI separately for each unrelated business. Not surprisingly, this new “silo rule” has led to some head-scratching. This article discusses interim guidance aimed at clearing up any confusion. Nonprofits may rely on this guidance (IRS Notice 2018-67) until proposed regulations are issued. A sidebar explains how the TCJA provisions on transportation fringe benefits, including transit and parking, are affecting organizations.