Proposed Regulations:UBTI “Siloing” Rules Under IRC Section 512(a)(6)


Course Description
Join us to discuss IRC Section 512(a)(6), referred to as the UBTI “siloing” rules, and the proposed regulations released on April 23, 2020. We will focus on the rules surrounding the separate computation of UBTI for trades and businesses held by nonprofit organizations. In addition, the session will cover changes imposed by the proposed regulations, including the use of two-digit NAICS codes, updates to investment activity reporting and the de minimis and control tests. The session is intended to provide a broad overview of the proposed regulations and the impact on UBTI reporting.

Learning Objectives:

  • Discuss the reporting requirements under IRC Section 512(a)(6) as imposed by the TCJA and clarified by the proposed regulations. 
  • Review the major provisions included in the proposed regulations, including use of two-digit NAICS Codes, reporting investment activities (de minimis and control tests), the transition rules and reporting of separate trades or businesses on the tax return. 
  • Discuss general NOL considerations with respect to the “siloing” of activities and recent legislation via the CARES Act.

Brenda Blunt, CPA, CGMA, Partner, Eide Bailly
Brenda provides services to nonprofit organizations, closely-held businesses and their stakeholders, and she represents clients before the Internal Revenue Service. She works with the preparation of individual, business, investment and nonprofit returns and assists with tax planning for clients moving into new lines of business, starting an enterprise or closing a line of operation or the entire organization. She is experienced in planning and minimization of unrelated business income tax for nonprofit organizations. 

Christine Perez, CPA, Manager, Eide Bailly
Christine is a manager in our exempt organization tax practice and a member of Eide Bailly’s National Tax Office. Christine has more than 10 years of public accounting experience working with a variety of tax-exempt organizations and assisting with tax compliance and strategy as well as providing technical research and analysis. She assists nonprofits with applications for and the reinstatement of tax-exempt status, unrelated business income studies, annual compliance and other tax-related issues.

CPE Information
CPE Credits: 1
Field of Study: Taxes
Level of Knowledge: Basic
Delivery Method: Group-Internet Based

Additional Information:This is a web-group seminar. No prerequisites or advanced preparation required. For information regarding refund, complaint and program cancellation policies, please contact Jason McKeever at 612.253.6628

CPE Sponsors

Stay current on your favorite topics


Learn More

See what more we can bring to organizations just like yours.


Take a deeper dive into this Insight’s subject matter.