My thought is that 3ABN probably needed to file a 990-T, not because of royalties but because of lease payments for the Subway restaurant, Tae Kwon Do place, and barber shop. I would think the leases from those places would be unrelated business income.
If 3ABN produced more than 3 years of documents because of one of the reasons given in that manual, then there is no way that there was no discrepancy or infraction.
Jog your "common sense" Bob in that leases are rents, just a little term differences. You're getting too technical and Bonnie said I wasn't even an auditor while Snoop locked the door behind. All of you have a tendendcy to be like some of my trainees in some of the largest banks, insurance companies, and whathaveyous that have cafeterias, childcare, and healthspas "onsite for the convenience of the employees" where the government doesn't even "strain at a gnat yet swollow a camel" like some of the "religious sort!" And, that can get bad on occasions!!!! And Bob, keep motels in re rents in mind if that becomes part of their business model in re exclusions. You only see some of this stuff on large taxpayers which comes from experience, but, I'm alleged to not even be an auditor.
Bob, I'd like to converse more directly with the informant if they could get through on a private message which some boards allow as one-ways even thought I would not return other than coded in public. I could then shed a little clarity on the "laughable exhoneration" being moronically slapped around on these threads.
Bob, you may need to consult with Snoopy on some of my less than auditor quality spin on this subject!
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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.
Additional information:
Additional reporting required by controlling organization that receives items of interest, royalties, or rents from controlled entities, under Internal Revenue Code section 512(b)(13).
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