Unrelated Business Income Tax (December 3, 2018)


The Church Alliance submitted a comment letter to the Internal Revenue Service concerning the Tax Cuts and Jobs Act provision, Code Section 512(a)(6), changing the calculation of the unrelated business income tax (UBIT). The comment letter suggests methods of compliance that reduce the burden on church plans, and recommends delay of implementation of the provision pending further guidance. In particular, the letter suggests raising the threshold percentage of ownership that would constitute “control” for purposes of determining when UBIT should be calculated separately for investments in different partnerships.