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Unrelated business taxable income (UBTI)

Hospital’s laboratory testing for patients of private physicians didn’t produce UBTI

Hospital’s laboratory testing for patients of private physicians didn’t produce UBTI

PLR 201428030 In a Technical Advice Memorandum (TAM), IRS has ruled that a tax-exempt hospital’s provision of laboratory testing for the patients of private physicians located in a medically under-served population didn’t generate unrelated business taxable income (UBTI). While such an activity would generally be an unrelated trade or business, it wasn’t in this case […]

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IRS rules on effects of private foundation owning an apartment complex

IRS rules on effects of private foundation owning an apartment complex

PLR 201422027. IRS has privately ruled on various unrelated business income tax and excess business holdings tax aspects of a private foundation owning an apartment complex that isn’t related to its exempt function. One such ruling was that net revenue from the complex’s coin-operated laundries was unrelated business taxable income (UBTI). Facts. The Taxpayer is […]

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Proposed regulation would clarify how to calculate certain benefit organizations’ UBTI

Proposed regulation would clarify how to calculate certain benefit organizations’ UBTI

Preamble to Prop Reg 02/05/2014; Prop Reg § 1.512(a)-5. IRS has issued a proposed reg on computing unrelated business taxable income (UBTI) of voluntary employees’ beneficiary associations (VEBAs) and supplemental unemployment benefit trusts (SUBs). The main change in the proposed reg, which would replace an existing temporary reg, is a clarification of the rule that […]

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Proposed regulation would clarify how to calculate certain benefit organizations’ unrelated business taxable income (UBTI)

Proposed regulation would clarify how to calculate certain benefit organizations’ unrelated business taxable income (UBTI)

Preamble to Prop Reg 02/05/2014; Prop Reg § 1.512(a)-5. IRS has issued a proposed reg on computing unrelated business taxable income (UBTI) of voluntary employees’ beneficiary associations (VEBAs) and supplemental unemployment benefit trusts (SUBs). The main change in the proposed reg, which would replace an existing temporary reg, is a clarification of the rule that […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney