Unrelated Business: Basic Rules
*§ 24.1 INTRODUCTION TO UNRELATED BUSINESS RULES
*p. 687, second complete paragraph, third line. Insert footnote following period:
11.1 See § 4.5(c).
*p. 689, note 29. Insert following existing text:
Thus, the IRS ruled that income to be received by a private foundation on satisfaction of debts of legal fees earned by its founder, now deceased, will not be unrelated business income because the foundation will only be a passive recipient of the income; the unrelated business that was regularly carried on to generate the fees was conducted by the founder's law firm, not the foundation (Priv. Ltr. Rul. 201626004).
*§ 24.2 DEFINITION OF TRADE OR BUSINESS
*(b) Requirement of Profit Motive
*p. 691, second complete paragraph, first line. Insert footnote following first sentence:
52.1 The instructions accompanying Form 990-T (see § 28.10) state: “Generally, an activity lacking a profit motive is one that is not conducted for the purpose of producing a profit or one that has consistently produced losses when both direct and indirect expenses are taken into account.”
*p. 692, note 56. Insert as first sentence:
A similar arrangement involved a religious ...