Not-for-profit (“NFP”) organizations must report and pay tax on unrelated business income (“UBI”), which is income earned from a trade or business that is not substantially related to the organization’s exempt purpose. Further, many NFP organizations also have intercompany transactions with for-profit, taxable affiliates. The IRS has the authority to review these transactions under Section 482 of the Internal Revenue Code and make any adjustments necessary to reflect arm’s length pricing.
