Proposed Regulations:UBTI “Siloing” Rules Under IRC Section 512(a)(6)

Course Description Join us to discuss IRC Section 512(a)(6), referred to as the UBTI “siloing” rules, and the proposed regulations released on April 23, 2020. We will focus on the rules surrounding the separate computation of UBTI for trades and businesses held by nonprofit organizations. In addition, the session will cover changes imposed by the proposed regulations, including the use of two-digit NAICS codes, updates to investment activity reporting and the de minimis and control tests. The session is intended to provide a broad overview of the proposed regulations and the impact on UBTI reporting. Learning Objectives: Discuss the reporting requirements under IRC Section 512(a)(6) as imposed by the TCJA and clarified by the proposed regulations. Review the major provisions included in the proposed regulations, including use of two-digit NAICS Codes, reporting investment activities (de minimis and control tests), the transition rules and reporting of separate trades or businesses on the tax return. Discuss general NOL considerations with respect to the “siloing” of activities and recent legislation via the CARES Act.