- 5 -
of all its affiliated bodies and regular members, acting as an
appellate body to resolve internal disputes among the affiliated
bodies and between regular members and affiliated bodies, and
negotiating and administering national collective bargaining
agreements in numerous industries that provide job opportunities
for regular members, and that are serviced by local union and
district councils in coordination with the Mail Handlers. The
above-listed activities benefited Mail Handlers during the years
in issue.
OPINION
We must decide whether the income received by petitioner in
the form of the per capita tax imposed on Mail Handlers and
calculated with reference to the number of associate members in
Mail Handlers constitutes UBTI under sections 511 through 513.
Petitioner is a section 501(c)(5) exempt organization. Section
511(a) imposes a tax on the UBTI of exempt organizations. In
relevant part, section 511(a) provides:
SEC.511(a). Charitable, etc., Organizations Taxable at
Corporation Rates.
(1) Imposition of tax.--There is hereby imposed
for each taxable year on the unrelated business taxable
income (as defined in section 512) of every
organization described in paragraph (2) a tax computed
as provided in section 11. In making such computation
for purposes of this section, the term “taxable income”
as used in section 11 shall be read as “unrelated
business taxable income”.
(2) Organizations subject to tax.--
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011