8/31/98: UBTI for the goose is UBTI for the gander. IRS Revenue Ruling 98-42 holds that a common trust fund investing in assets that produce "unrelated business taxable income" (UBTI) can produce UBTI in the hands of a qualified plan trust fund that invests in that common trust fund. This result is required by 1980 IRS regulations under section 584 of the Code pertaining to common trust funds, but Rev. Rul 98-42 expressly modifies a 1967 revenue ruling that seems to be inconsistent with the 1980 regulations.
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