IRS Addresses Post-TCJA Calculations of UBTI for VEBAs and SUBs | Practical Law
The Internal Revenue Service (IRS) has issued proposed regulations addressing how certain tax-exempt entities, including voluntary employees' beneficiary associations (VEBAs) and supplemental unemployment benefit (SUB) trusts, determine if they have more than one unrelated trade or business and, if so, how these entities calculate their unrelated business taxable income (UBTI). The regulations reflect statutory changes under the Tax Cuts and Jobs Act (TCJA), which was enacted in December 2017.