This Insights blog is Part 3 of a 3-Part series focused on the unrelated business income tax rules for the nonprofit organization that is tax-exempt pursuant to section 501(c)(3) of the Internal Revenue Code (the “Code”).
Part 1—Tax Exemption and the Framework for the Unrelated Business Income Rules—provided an overview of the organizational and operational tests of section 501(c)(3) of the Code and alluded to the trigger for unrelated business income rules. Part 2–Unrelated Business Income Tax Rules, Modifications, and Exceptions—dived deeper into, well, the specific rules, modifications, and exceptions.
This Part 3 will dive deeper into the meaning of a trade or business that is “substantially related” to an exempt purpose of the tax-exempt organization.
“Substantially Related.”
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