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Proposed Regs Incorporate IRS Litigation Position on UBTI for VEBAs and SUB Trusts
Sutherland Asbill & Brennan LLP Link to more items from this source
[Guidance Overview]
Feb. 13, 2014
"The principal objective of the reproposal is to state expressly in regulations the IRS position that investment income earned during a taxable year is subject to UBTI if the organization's year-end assets exceed the account limit under IRC section 419A for that year (without taking into account any post-retirement medical reserve).... The reproposal would clarify the regulation with respect to the method the IRS views as correct for calculating UBTI, to take account of such investment income, and add examples clearly illustrating this approach."

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