In this third year of having to define (and report on) "separate unrelated trades or businesses," the tasks remain daunting. This session will focus primarily on the hard questions practitioners face in grouping unrelated activities by type both generically and by relationship. We'll cover issues in characterizing partnerships and categorizing their income streams, handling investment income hiccups, and various quirks that guidance has answered (or not answered) for various UBI sub-sector rules. Come prepared to "know you are not alone" and to field tips and suggestions for making life easier.
Understand the aspects and factors by which unrelated activities may be grouped generically or relationally
Appreciate the conditions by which pass-through UBIT revenue streams are properly assignable to stand-alone silos versus characterized by activity type
Principal (ERB LLC) / Of Counsel (Harmon Curran),
Eve Rose Borenstein LLC (training/speaking) / Harmon Curran Spielberg & Eisenberg LLP (legal practice)