The IRS on April 23 released proposed regulations (Proposed Regulations) under Section 512(a)(6) requiring segmentation of unrelated business taxable income (UBTI). The Proposed Regulations adopt aspects of interim guidance in Notice 2018-67, including:
Although the Proposed Regulations are not yet binding, organizations should consider analyzing their potential impact on their UBTI reporting. Organizations may consider submitting comments to the IRS in response to the Proposed Regulations.
Health Services Tax Leader, PwC US