Unrelated business income tax (UBIT) services for nonprofits.

years of nonprofit-exclusive practice

nonprofit clients served

nonprofit professionals

client retention rate

Recurring screening,
not one-time.

Recurring screening,
not one-time.

We screen each of your revenue streams individually against the IRS’s three-part test, prepare Form 990-T filings where unrelated business income applies, and reassess exposure on a recurring cycle as your programs and revenue activities evolve.

What revenue streams do nonprofits most often misjudge

What revenue streams do nonprofits most often misjudge?

Facility rentals, advertising revenue in publications or on websites, and fees from programs adjacent to the core mission are the activities nonprofits most commonly misjudge on UBIT. The mistake usually is not carelessness. These activities genuinely look mission-supportive on the surface, and the IRS’s test for whether they are taxable is not intuitive without specific expertise.

The risk compounds because these revenue streams often grow gradually. An organization might rent unused space occasionally at first, then more regularly as the arrangement proves reliable, crossing from incidental activity into something “regularly carried on” without anyone flagging the shift. By the time a UBIT question surfaces, often during an audit or a new controller’s first close, multiple years of unreported liability may already exist.

What actually triggers UBIT?

The IRS applies a three-part test. All three conditions must be met for income to be taxable as unrelated business income:

The third prong is where most judgment calls happen. An activity can be revenue-generating and mission-adjacent without qualifying as substantially related. The test asks whether the activity itself contributes importantly to the exempt purpose, not whether the revenue it produces funds exempt activities.

What does UBIT screening include?

Activity-by-activity screening.

Each of an organization’s revenue streams is evaluated individually against the three-part test. A blanket assessment across all revenue is not sufficient because UBIT applies at the activity level, and one organization can have both taxable and non-taxable revenue from activities that look superficially similar.

Sponsorship vs. advertising analysis.

Qualified corporate sponsorship payments, where the sponsor receives acknowledgment but not substantial advertising benefits, are generally excluded from UBIT. The distinction between simple acknowledgment and taxable advertising depends on exactly what the sponsor receives in exchange. We evaluate sponsorship arrangements individually because the line is fact-specific.

Royalty & licensing review.

Royalty income is generally excluded from UBIT, but arrangements that involve services beyond the licensing of intellectual property can reclassify the income as taxable. We review licensing and royalty arrangements to confirm they qualify for the exclusion.

Debt-financed income analysis.

Income from property acquired or improved with borrowed funds may be subject to UBIT even if the underlying activity is otherwise exempt. We identify debt-financed income exposure and calculate the taxable portion where it applies.

Form 990-T preparation.

When UBIT applies, we prepare the required return, including the tax calculation and any applicable deductions directly connected to the unrelated activity.

Ongoing monitoring.

We reassess revenue streams on a recurring basis, since a new program, partnership, or operational change can shift an activity’s UBIT status without anyone recognizing it at the time.

How do we screen for UBIT exposure?

Revenue stream inventory.

We catalog every distinct revenue source the organization has, including those that seem clearly mission-related.

Three-part test application.

We apply the trade-or-business, regularly-carried-on, and substantially-related tests to each stream individually.

Exclusion review.

We evaluate whether any applicable exclusions (volunteer labor, donated merchandise, passive investment income, qualified sponsorship) apply to activities that otherwise meet the test.

Form 990-T preparation.

Where UBIT applies, we prepare the return and calculate the tax owed.

Ongoing monitoring cadence.

We reassess revenue streams on a recurring cycle, catching gradual shifts in activity volume or character before they create multi-year exposure.

The Nonprofit 
Leadership Exchange.

Related services.

Frequently asked questions.

UBIT is a tax on income a nonprofit earns from an activity that is a trade or business, regularly carried on, and not substantially related to its tax-exempt purpose. Even a tax-exempt organization can owe tax on certain revenue streams.

Common triggers include renting facilities or parking on a regular basis, selling advertising space unrelated to the mission, providing commercial services to the general public, and debt-financed investment income. Each activity is evaluated individually.

Yes. While occasional or modest unrelated business income typically creates only a tax liability, an organization where unrelated business activity becomes a substantial portion of overall operations risks its exempt status being challenged.

Unrelated business taxable income (UBTI) is generally calculated based on income from unrelated trade or business activities, reduced by allowable deductions directly connected with those activities. If an organization operates more than one unrelated trade or business, UBTI generally must be calculated separately for each activity under the IRS “siloing” rules, which can limit the ability to use losses from one unrelated business to offset income from another. UBIT is reported on Form 990-T, which is filed separately from the organization’s regular Form 990-series return.

Qualified corporate sponsorship payments, where the sponsor receives acknowledgment but not substantial advertising benefits, are generally excluded. The distinction between acknowledgment and taxable advertising depends on the specific benefits the sponsor receives in return. The analysis is fact-specific to each arrangement.

Revenue from activities conducted substantially by volunteers, from the sale of donated merchandise, and from certain passive investment income (dividends, interest, qualified royalties) are commonly excluded even when they resemble commercial activity.