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Non-Profit Business Activity and the Unrelated Business Income Tax

In: Tax Policy and the Economy, Volume 13

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  • James R. Hines Jr.

Abstract

American nonprofit organizations are generally exempt from federal income tax, with the exception that profits earned from activities that are subject to the Unrelated Business Income Tax (UBIT). The UBIT is intended to prevent nonprofits and taxable for-profit firms, and also to prevent erosion of the federal tax base through tax-motivated transactions between taxable and tax-exempt entities. The evidence indicates that American nonprofit organizations engage in very little unrelated business activity, paying aggregate UBIT of less than $200 million annually. Large nonprofit organizations, and those with pressing financial needs due to high program-related expenses and low receipts of contributions and government grants, are the most likely to have unrelated business income. The same organizational characteristics are not associated with earning income from inventory sales that are nonprofits incur important organizational costs in undertaking unrelated business activity, since unrelated business income is concentrated among organizations facing the strongest financial pressures. This, in turn, carries implications for the efficiency of the UBIT as a source of tax revenue and for the need to tax the business income of nonprofit organizations in order to prevent
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Suggested Citation

  • James R. Hines Jr., 1999. "Non-Profit Business Activity and the Unrelated Business Income Tax," NBER Chapters, in: Tax Policy and the Economy, Volume 13, pages 57-84, National Bureau of Economic Research, Inc.
    • Handle: RePEc:nbr:nberch:10921
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    References listed on IDEAS

    as
    1. Sansing, Richard, 1998. "The Unrelated Business Income Tax, Cost Allocation, and Productive Efficiency," National Tax Journal, National Tax Association, vol. 51(n. 2), pages 291-302, June.
    2. Gary Chamberlain, 1980. "Analysis of Covariance with Qualitative Data," The Review of Economic Studies, Review of Economic Studies Ltd, vol. 47(1), pages 225-238.
    3. Sansing, Richard, 1998. "The Unrelated Business Income Tax, Cost Allocation, and Productive Efficiency," National Tax Journal, National Tax Association;National Tax Journal, vol. 51(2), pages 291-302, June.
    4. Joseph J. Cordes & Burton A. Weisbrod, "undated". "Differential Taxation of Nonprofits and the Commercialization of Nonprofit Revenues," IPR working papers 97-15, Institute for Policy Resarch at Northwestern University.
    5. Stiglitz, Joseph E., 1973. "Taxation, corporate financial policy, and the cost of capital," Journal of Public Economics, Elsevier, vol. 2(1), pages 1-34, February.
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    Cited by:

    1. Mihir A. Desai & Robert J. Yetman, 2005. "Constraining Managers without Owners: Governance of the Not-for-Profit Enterprise," NBER Working Papers 11140, National Bureau of Economic Research, Inc.
    2. Duquette, Nicolas J., 2016. "Do tax incentives affect charitable contributions? Evidence from public charities' reported revenues," Journal of Public Economics, Elsevier, vol. 137(C), pages 51-69.
    3. Jonathan Oxley, 2021. "Does Additional Mandatory Reporting Alter Charity or Donor Behavior?---Examining the 2006 Pension Protection Act," Working Papers wp2021_01_02, Department of Economics, Florida State University.
    4. Maxim Sinitsyn & Burton A. Weisbrod, 2008. "Behavior of Nonprofit Organizations in For-Profit Markets: The Curious Case of Unprofitable Revenue-Raising Activities," Journal of Institutional and Theoretical Economics (JITE), Mohr Siebeck, Tübingen, vol. 164(4), pages 727-750, December.
    5. Oxley, Jonathan, 2022. "Does additional mandatory reporting alter charity or donor behavior? Examining the 2006 Pension Protection Act," Journal of Economic Behavior & Organization, Elsevier, vol. 200(C), pages 738-751.

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    More about this item

    JEL classification:

    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • L31 - Industrial Organization - - Nonprofit Organizations and Public Enterprise - - - Nonprofit Institutions; NGOs; Social Entrepreneurship

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