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Tag Archives: qualified asset account limit

Controversial Issue of UBTI for VEBAs Addressed in §512(a)(3)(E) and Treas. Reg. §1.512(a)-5T

Posted on February 27, 2012 by Carla Neeley Freitag

Code section 512(a)(3)(E) and Treas. Reg. §1.512(a)-5T address the computation of the unrelated business taxable income of voluntary employees’ beneficiary associations (VEBAs) described in §501(c)(9). The provisions also apply to supplemental unemployment compensation benefit trusts (SUBs) described in §501(c)(17).

 §512(a)(3)(E). Unrelated business taxable income for social clubs, VEBAs, and SUBs is calculated differently than for most other exempt organizations. Continue reading →

Posted in Regulations, UBTI | Tagged Deficit Reduction Act of 1984, exempt function income, IRS priority Guidance Plan, qualified asset account limit, set aside, social club, supplemental unemployment compensation benefit trust, UBIT, UBTI, VEBA, voluntary employees' beneficiary association

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agricultural organization corporations debt-financed income debt-financed property Deficit Reduction Act of 1984 DFI dividends exclusion dues educational organization endowment fund estates and trusts exempt function income exempt organizations exempt purposes Form 990 Form 990-T horticultural organization IRS priorities IRS priority Guidance Plan los cost articles members neighborhood land rule payments from controlled entities qualified asset account limit rental exclusion set aside social club supplemental unemployment compensation benefit trust tax exemption tax reform trade or business UBIT UBIT compliance UBIT education UBIT rates UBTI UBTI modifications undowment units unitrust universities unrelated business income tax unrelated business taxable income unrelated trade or business VEBA voluntary employees' beneficiary association

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