Sec. 112024. Unrelated business taxable income increased by amount of certain fringe benefit expenses for which deduction is disallowed
241 words·~1 min read·
/bill/119/hr/1/eh/section-112024·A research copy — for the controlling text, always check the official state or federal source. Not legal advice.
Section 512(a) is amended by adding at the end the following new paragraph: Unrelated business taxable income of an organization shall be increased by any amount— which is paid or incurred by such organization for any qualified transportation fringe (as defined in section 132(f)) or any parking facility used in connection with qualified parking (as defined in section 132(f)(5)(C)), which is not directly connected with an unrelated trade or business which is regularly carried on by the organization, and for which a deduction is not allowable under this chapter by reason of section 274. Subparagraph
(A)shall not apply to— any organization to which section 6033(a)(1) does not apply by reason of clause
(i)or
(iii)of section 6033(a)(3)(A), and any church-affiliated organization described in section 501(c) which is not required to file an annual return under section 6033(a)(1) by reason of section 6033(a)(3)(B). For purposes of paragraph (6), any increase under subparagraph
(A)shall be treated as unrelated business taxable income with respect to an unrelated trade or business separate from any other unrelated trade or business of the organization. The Secretary shall issue such regulations or other guidance as may be necessary or appropriate to carry out the purposes of this paragraph, including regulations or other guidance providing for the appropriate allocation of costs with respect to facilities used for parking. . The amendment made by this section shall apply to amounts paid or incurred after December 31, 2025.