By
Kathleen Stephenson
and Lisa Petkun
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Among the many issues that must be considered by the charity — in addition to whether such an arrangement makes sense financially — are potential taxation questions concerning unrelated business-income tax (UBIT) issues and private-benefit rules.
A nonprofit organization that realizes income from a trade or business that is unrelated to its charitable purposes will be deemed to have UBIT and be subject to tax on that income at corporate tax rates.
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Kathleen Stephenson
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Lisa Petkun
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