Once a taboo word in the tax-exempt landscape, unrelated business taxable income (UBTI) has gained significant traction. We have assisted many of our clients in structuring UBTI generating activities in a manner that does not endanger their tax-exempt status but produces new capital to invest into their tax-exempt missions. When “too much” UBTI is generated, we have assisted clients with spinning-off or proactively forming for-profit subsidiaries. We have also assisted our clients with structuring joint-ventures with for-profit entities in a manner that preserves the tax-exemption of the income generated and passed through to the tax-exempt participant.
