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Irs efile Publication 570 - Additional Material Table of Contents This image is too large to be displayed in the current screen. Irs efile Please click the link to view the image. Irs efile Tax Publications for Business Taxpayers Prev  Up  Next   Home   More Online Publications
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Irs efile 1. Irs efile   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). Irs efile 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). Irs efile In addition, the following are subject to the tax on unrelated business income. Irs efile 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). Irs efile State and municipal colleges and universities. Irs efile Qualified state tuition programs. Irs efile Medical savings accounts (MSAs) described in section 220(d). Irs efile Coverdell savings accounts described in section 530. Irs efile U. Irs efile S. Irs efile instrumentalities. Irs efile   A corporation that is a U. Irs efile S. Irs efile 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. Irs efile Colleges and universities. Irs efile   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. Irs efile 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). Irs efile   The tax is on the unrelated business income of both the universities and colleges themselves and on their wholly owned tax exempt subsidiary organizations. Irs efile It is immaterial whether the business is conducted by the university or by a separately incorporated wholly owned subsidiary. Irs efile If the business activity is unrelated, the income in both instances will be subject to the tax. Irs efile 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. Irs efile Title-holding corporations. Irs efile   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. Irs efile   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. Irs efile However, if the source of the income is not so related, the title-holding corporation is subject to unrelated business income tax. Irs efile Example. Irs efile X, a title-holding corporation, is required to distribute its net income to A, an exempt organization. Irs efile During the tax year, X realizes net income of $900,000 from source M, which is related to A's exempt function. Irs efile X also receives $100,000 from source N, which is not related to A's exempt function. Irs efile X and A file a consolidated return for the tax year. Irs efile X has unrelated business income of $100,000. Irs efile Prev  Up  Next   Home   More Online Publications