ITG FAQ #9 Answer-Are there any allocation requirements?
What happens when an individual tribal member or a qualified Indian entity is engaged in both fishing rights-related activities and the harvesting of fish not through the exercise of protected fishing rights?
In this case, IRC section 7873 exempts from tax only that income derived from fishing rights-related activities. Therefore, both individual tribal members and qualified Indian entities are required to allocate income and expenses among fishing rights-related activities and all other activities.
Note: Expenses and amounts otherwise deductible that are attributable to such exempt income cannot be used to offset income from other activities.