Laborers' International Union of North America - Page 5

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          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.                                                                   
               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.--                               

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