Exempt Organizations Technical Guide›TG 48: Unrelated Business Income Tax›Table of Contents
D. Organizations Subject to Tax
Publication 5894 — Exempt Organizations Technical Guides TG 48: Unrelated Business Income Tax · 2026-10-03 edition · updated 2026-10-04 · United States
(1) The tax on unrelated business income applies to all organizations exempt from
taxation under Section 501(a) (except United States instrumentalities described in Section 501(c)(1)) or trusts described in Section 401(a)) plus state colleges, municipal colleges and universities. See Section 511(a)(2). In addition, there
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are special rules for taxing the unrelated business income of title-holding corporations described in Section 501(c)(2). See Section 511(c).
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