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The Free Tax 2007
Free tax 2007 1. Free tax 2007 Organizations Subject to the Tax Table of Contents The tax on unrelated business income applies to most organizations exempt from tax under section 501(a). Free tax 2007 These organizations include charitable, religious, scientific, and other organizations described in section 501(c), as well as employees' trusts forming part of pension, profit-sharing, and stock bonus plans described in section 401(a). Free tax 2007 In addition, the following are subject to the tax on unrelated business income. Free tax 2007 Individual retirement arrangements (IRAs), including traditional IRAs, Roth IRAs, Coverdell IRAs, simplified employee pensions (SEP-IRAs), and savings incentive match plans for employees (SIMPLE IRAs). Free tax 2007 State and municipal colleges and universities. Free tax 2007 Qualified state tuition programs. Free tax 2007 Medical savings accounts (MSAs) described in section 220(d). Free tax 2007 Coverdell savings accounts described in section 530. Free tax 2007 U. Free tax 2007 S. Free tax 2007 instrumentalities. Free tax 2007 A corporation that is a U. Free tax 2007 S. Free tax 2007 instrumentality described in section 501(c)(1) is not subject to the tax on unrelated business income if the corporation is organized under an Act of Congress and, under the Act, is exempt from federal income taxes. Free tax 2007 Colleges and universities. Free tax 2007 Colleges and universities that are agencies or instrumentalities of any government or any political subdivision of a government, or that are owned or operated by a government or political subdivision of a government, are subject to the tax on unrelated business income. Free tax 2007 As used here, the word government includes any foreign government (to the extent not contrary to a treaty) and all domestic governments (the United States and any of its possessions, any state, and the District of Columbia). Free tax 2007 The tax is on the unrelated business income of both the universities and colleges themselves and on their wholly owned tax exempt subsidiary organizations. Free tax 2007 It is immaterial whether the business is conducted by the university or by a separately incorporated wholly owned subsidiary. Free tax 2007 If the business activity is unrelated, the income in both instances will be subject to the tax. Free tax 2007 If the primary purpose of a wholly owned subsidiary is to operate or conduct any unrelated trade or business (other than holding title to property and collecting income from it), the subsidiary is not an exempt organization, and this rule does not apply. Free tax 2007 Title-holding corporations. Free tax 2007 When an exempt title-holding corporation, described in section 501(c)(2), pays any of its net income to an organization that itself is exempt from tax under section 501(a) (or would pay such an amount except that the expenses of collecting its income exceed the amount collected) and files a consolidated return with that organization, the title-holding corporation is treated, for unrelated business income tax purposes, as organized and operated for the same purposes as the exempt payee organization. Free tax 2007 Thus, a title-holding corporation whose source of income is related to the exempt purposes of the payee organization is not subject to the unrelated business income tax if the holding corporation and the payee organization file a consolidated return. Free tax 2007 However, if the source of the income is not so related, the title-holding corporation is subject to unrelated business income tax. Free tax 2007 Example. Free tax 2007 X, a title-holding corporation, is required to distribute its net income to A, an exempt organization. Free tax 2007 During the tax year, X realizes net income of $900,000 from source M, which is related to A's exempt function. Free tax 2007 X also receives $100,000 from source N, which is not related to A's exempt function. Free tax 2007 X and A file a consolidated return for the tax year. Free tax 2007 X has unrelated business income of $100,000. Free tax 2007 Prev Up Next Home More Online Publications