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The IRS on "Substantially Related"

One of the factors to determine if a credit union will fall under UBIT is if the activity is not "substantially related" to its purpose. That's an area that could be open to interpretation as noted in the story in terms of the IRS' challenge of credit insurance. The following...

By Staff Writer | Updated on March 25, 2003

One of the factors to determine if a credit union will fall under UBIT is if the activity is not “substantially related” to its purpose. That’s an area that could be open to interpretation as noted in the story in terms of the IRS’ challenge of credit insurance. The following excerpt is from an IRS document touching on the “substantially required” aspect: “To determine whether a business activity is or is not “substantially related” requires an examination of the relationship between the business activities that generate the particular income in question and the accomplishment of the organization’s exempt purpose. Trade or business is related to exempt purposes, in the statutory sense, only when the conduct of the business activities has causal relationship to the achievement of exempt purposes (other than through the production of income). The causal relationship must be substantial. The activities that generate the income must contribute importantly to the accomplishment of the organization’s exempt purposes to be substantially related.”

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