(c)(3)’s commissions on services generate UBIT

(c)(3)’s commissions on services generate UBIT

The commissions paid to a hospital association by vendors providing debt collection and group purchasing services to its members are subject to unrelated business income tax, the Tax Court has ruled.  They are not considered substantially related to the exempt purpose of the association and are not excluded from unrelated business income either as “royalties” or as activities carried on primarily “for the convenience” of its members.

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