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'Tax Cuts' Act Raises the Tax on Funds Generating UBTI (PDF)
Groom Law Group in planadviser; registration may be required Link to more items from this source
[Guidance Overview]
May 8, 2019

"The tax code now requires that the trust or VEBA calculate gains and losses of each 'trade or business.' In the absence of regulations or additional guidance from the Treasury Department or the IRS providing otherwise, the IRC now appears to require that a trust or VEBA treat each investment fund as a separate trade or business. Therefore, the ability to calculate gains and losses on a net basis is lost. Further, the trust or VEBA may not use future NOLs generated by one fund to offset gains generated by another fund."  MORE >>

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