UBIT to the Defense! ESOPs and Government Entities

Calvin H. Johnson Ellen P. Aprill The unrelated trade or unrelated business income tax imposes tax on the unrelated business income of tax exempt organizations, including charities and pension plans. The general principle is that tax is imposed on business income no matter what its use or destination.UBIT defends the tax base by preventing the shift of business assets from taxable corporations to exempt entities. Employee stock ownership plans (ESOP),…