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UBTI |
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An initial review suggests that more NPOs may now have payments taxed as UBTI under these new guidelines. The Absolute Return Fund STS leverages the attractiveness of the Absolute Return Fund, while ensuring that UBTI is not ultimately incurred by the investor as a result of the Absolute Return Fund's investment activities," said Stuart Bohart, Head of Alternative Investments of Morgan Stanley Investment Management. For example, distributions out of the earnings and profits of a real estate investment trust were dividends exempt in computing UBTI (Rev. |
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