Читать книгу The Tax Law of Charitable Giving - Bruce Hopkins R., Bruce R. Hopkins, David Middlebrook - Страница 53

Certain types of income are exempt from the unrelated business income tax.⁵⁶²

Because the unrelated business income rules apply to active business conducted by tax-exempt organizations, most types of passive income are exempt from taxation. This exemption, euphemistically embraced by the concept of modifications, generally covers income such as dividends, interest, payments with respect to securities loans, annuities, royalties, most rents, capital gains, and gains on the lapse or termination of options written by the organization.⁵⁶³

The unrelated debt-financed income rules, however, override the general exception for passive income.⁵⁶⁴ Also, interest, annuities, royalties, and rents derived from a controlled corporation may be taxable.⁵⁶⁵ It should be noted that there are three exceptions pertaining to research income.⁵⁶⁶ A specific deduction of $1,000 is available for any type of unrelated business income.⁵⁶⁷