Tax Alert: Treasury Department Issues Proposed Regulations for Unrelated Business Income Silo Rules Under Section 512(a)(6)
Late last week, the Treasury Department and Internal Revenue Service issued long-awaited proposed regulations (IR-2020-78) to outline the application of Section 512(a)(6) of the Internal Revenue Code established by Congress in December of 2017 as part of the Tax Cuts and Jobs Act.
We recently shared a tax alert discussing these proposed regulations.