The U.S. IRS has published Notice 2018-67, requesting comments regarding the application of new § 512(a)(6) of the Internal Revenue Code ("Code"), which was added to the Code by the Tax Cuts and Jobs Act.
Section 512(a)(6) requires an organization subject to the unrelated business income tax under § 511 with more than one unrelated trade or business to calculate unrelated business taxable income ("UBTI") separately with respect to each trade or business. The notice requests comm…