Unrelated Business Income (UBI)
GKG Law’s Association Practice Group assists tax-exempt clients seeking to broaden the scope of their revenue-generating activities, both as a means of carrying out their missions and generating revenue to support their missions. We evaluate and structure new business opportunities in a manner that mitigates the risk that such revenue will be taxable as unrelated business income. Additionally, we obtain IRS rulings characterizing income from certain association activities to be related income not subject to tax, and, when necessary, we resolve unrelated business income tax issues at the IRS appeals level and successfully litigate these issues in Federal courts.