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Exempt Organizations Technical Guide›TG 48: Unrelated Business Income Tax›Table of Contents

B.1. General

Publication 5894 — Exempt Organizations Technical Guides TG 48: Unrelated Business Income Tax · 2026-10-03 edition · updated 2026-10-04 · United States

(1) In determining whether a trade or business from which a particular amount of

gross income derives is "regularly carried on" within the meaning of Section 512, regard must be made to the frequency and continuity with which the

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activities productive of the income are conducted and the manner in which they are pursued. This requirement must be applied in light of UBIT’s purpose to place exempt organizations’ business activities upon the same tax basis as the nonexempt business endeavors with which they compete. So, for example, specific business activities of an exempt organization are ordinarily deemed to be "regularly carried on" if they manifest a frequency and continuity and are pursued in a manner generally similar to comparable commercial activities of nonexempt organizations. See Treas. Reg. 1.513-1(c)(1).

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▸Contents — Publication 5894 — Exempt Organizations Technical Guides TG 48: Unrelated Business Income Tax

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