United States

The new unrelated trade or business loss offset prohibition


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The new law limiting losses from one trade or business to offset another for unrelated business income (UBI) purposes has many catches as well as opportunities for exempt organizations. As you navigate this new approach to calculating taxable income and begin to think about its application, you can’t help but wonder why the law is so vague in so many different places. In our white paper, The new unrelated trade or business loss offset prohibition, we introduce you to the new law contained in section 512(a)(6) and touch on some unanswered questions and issues which must be addressed in any future guidance issued by the IRS. The analysis also addresses the new net operating loss rules and presents questions that arise when both of these new rules interact with each other.  



Bob Billig
National Practice Leader

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