“An Analysis of Corporate Sponsorship of Tax-Exempt Organizations and the Unrelated Business Income Tax”
Brian K. Leonard

Throughout the history of the unrelated business income tax (“UBIT”), corporate sponsorship of exempt organizations has been a controversial issue. This is because of the competing interests of corporate responsibility and citizenship and tax policy implications. Thus, this paper will examine this area of law and taxation and discuss how Congress, the courts, and the IRS have struggled to strike the right balance in between establishing consistent and appropriate tax regulations and the encouragement of funding for tax-exempt organizations. This paper will examine the history of corporate sponsorships and the UBIT, including the laws, cases, and regulations that have been promulgated in this area. In addition this paper will highlight the reality that due to the importance of these sponsorships to exempt organizations, and the resulting political sentiment surrounding them, it is unlikely that they will ever be completely subject to the UBIT, and as a result the debate over the taxation of these activities will continue for the foreseeable future.

Full Text: PDF     DOI: 10.15640/ijat.v3n1a1