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Filing Tax ExtensionFiling tax extension 1. Filing tax extension Organizations Subject to the Tax Table of Contents The tax on unrelated business income applies to most organizations exempt from tax under section 501(a). Filing tax extension These organizations include charitable, religious, scientific, and other organizations described in section 501(c), as well as employees' trusts forming part of pension, profit-sharing, and stock bonus plans described in section 401(a). Filing tax extension In addition, the following are subject to the tax on unrelated business income. Filing tax extension Individual retirement arrangements (IRAs), including traditional IRAs, Roth IRAs, Coverdell IRAs, simplified employee pensions (SEP-IRAs), and savings incentive match plans for employees (SIMPLE IRAs). Filing tax extension State and municipal colleges and universities. Filing tax extension Qualified state tuition programs. Filing tax extension Medical savings accounts (MSAs) described in section 220(d). Filing tax extension Coverdell savings accounts described in section 530. Filing tax extension U. Filing tax extension S. Filing tax extension instrumentalities. Filing tax extension A corporation that is a U. Filing tax extension S. Filing tax extension instrumentality described in section 501(c)(1) is not subject to the tax on unrelated business income if the corporation is organized under an Act of Congress and, under the Act, is exempt from federal income taxes. Filing tax extension Colleges and universities. Filing tax extension Colleges and universities that are agencies or instrumentalities of any government or any political subdivision of a government, or that are owned or operated by a government or political subdivision of a government, are subject to the tax on unrelated business income. Filing tax extension As used here, the word government includes any foreign government (to the extent not contrary to a treaty) and all domestic governments (the United States and any of its possessions, any state, and the District of Columbia). Filing tax extension The tax is on the unrelated business income of both the universities and colleges themselves and on their wholly owned tax exempt subsidiary organizations. Filing tax extension It is immaterial whether the business is conducted by the university or by a separately incorporated wholly owned subsidiary. Filing tax extension If the business activity is unrelated, the income in both instances will be subject to the tax. Filing tax extension If the primary purpose of a wholly owned subsidiary is to operate or conduct any unrelated trade or business (other than holding title to property and collecting income from it), the subsidiary is not an exempt organization, and this rule does not apply. Filing tax extension Title-holding corporations. Filing tax extension When an exempt title-holding corporation, described in section 501(c)(2), pays any of its net income to an organization that itself is exempt from tax under section 501(a) (or would pay such an amount except that the expenses of collecting its income exceed the amount collected) and files a consolidated return with that organization, the title-holding corporation is treated, for unrelated business income tax purposes, as organized and operated for the same purposes as the exempt payee organization. Filing tax extension Thus, a title-holding corporation whose source of income is related to the exempt purposes of the payee organization is not subject to the unrelated business income tax if the holding corporation and the payee organization file a consolidated return. Filing tax extension However, if the source of the income is not so related, the title-holding corporation is subject to unrelated business income tax. Filing tax extension Example. Filing tax extension X, a title-holding corporation, is required to distribute its net income to A, an exempt organization. Filing tax extension During the tax year, X realizes net income of $900,000 from source M, which is related to A's exempt function. Filing tax extension X also receives $100,000 from source N, which is not related to A's exempt function. Filing tax extension X and A file a consolidated return for the tax year. Filing tax extension X has unrelated business income of $100,000. Filing tax extension Prev Up Next Home More Online Publications
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