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UBTI |
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Almost as an aside, the Ruling concludes that payments for the use of parking spaces would not be excluded from unrelated business taxable income under IRC Section 512(b)(3) if the taxpayer were an exempt organization. 664(c), which significantly alters the tax treatment of unrelated business taxable income (UBTI) received by a CRT in tax years ending after 2006. Unrelated business taxable income is the gross income derived by an organization from any unrelated trade or business it regularly carries on. |
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