Bulletin No. 2018–36 September 4, 2018

rately with respect to each trade or business. The notice requests comments on various topics, including possible methods for separating trades or businesses and the treatment of activities in the nature of investments and income from fringe benefits required to be included in UBTI under § 512(a)(7) for purposes of § 512(a)(6). The notice also sets forth interim and transition rules under § 512(a)(6) with respect to aggregating gross income and directly connected deductions of certain activities in the nature of investments. Finally, the notice concludes that global intangible low-taxed income (“GILTI”) under new § 951A will be treated in the same manner as subpart F inclusions under § 951(a)(1)(A) for purposes of the unrelated business income tax.