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Unrelated Business Income Tax Exceptions and Exclusions

The Internal Revenue Code contains a number of modifications, exclusions, and exceptions to unrelated business income. For example, dividends, interest, certain other investment income, royalties, certain rental income, certain income from research activities, and gains or losses from the disposition of property are excluded when computing unrelated business income. In addition, the following activities are specifically excluded from the definition of unrelated trade or business:

  • Volunteer Labor: Any trade or business is excluded in which substantially all the work is performed for the organization without compensation. Some fundraising activities, such as volunteer operated bake sales, may meet this exception.
  • Convenience of Members: Any trade or business is excluded that is carried on by an organization described in section 501(c)(3) or by a governmental college or university primarily for the convenience of its members, students, patients, officers, or employees.  A typical example of this is a school cafeteria.
  • Selling Donated Merchandise: Any trade or business is excluded that consists of selling merchandise, substantially all of which the organization received as gifts or contributions.  Many thrift shop operations of exempt organizations would meet this exception.
  • Bingo: Certain bingo games are not unrelated trade or business.

Additional information

Income from controlled entities included in unrelated business income


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Page Last Reviewed or Updated: 17-Apr-2014