Transfer Pricing for Not-For-Profit Organizations

Barry Freeman, PhD, and Nicole Bencik

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.

Transfer Pricing for Not-For-Profit Organizations

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