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US tax reform for exempt organizations: know the risks and how to avoid them

Blue J Legal


As a result of the US Tax Cuts and Jobs Act 2017, tax-exempt organizations are no longer able to aggregate gross income from multiple unrelated trades or businesses for the purposes of calculating their unrelated business taxable income. Thus, exempt taxpayers may now be at risk of costly consequences of unintentionally engaging in an unrelated trade or business.

With no statutory definition of the term ‘trade or business’ and no further guidance from Congress or the IRS, exempt taxpayers may be left wondering: when does a particular activity constitute a separate trade or business?

This webinar will cover:

  • The current state of the unrelated business income tax and Section 512(a)(6) of the Internal Revenue Code
  • Important implications of the Tax Cuts and Jobs Act for tax-exempt taxpayers
  • How machine learning can reduce uncertainty in tax positions in this area


Benjamin Alarie
CEO, Blue J Legal

Benjamin Alarie is CEO of Blue J Legal and a full professor at the University of Toronto, where he holds the Osler Chair in Business Law. He researches and teaches in taxation law and judicial decision making, and was awarded the Alan Mewett QC Prize for excellence in teaching by the law school’s 2009 graduating class. Before becoming a full-time professor in 2004, he completed graduate work at the Yale Law School and was a law clerk for Madam Justice Louise Arbour at the Supreme Court of Canada. He has dozens of academic publications to his name and his research has been funded by the Social Sciences and Humanities Research Council, the Canadian Foundation for Innovation and the Ontario Ministry of Research and Innovation. He has co-authored several editions of a leading legal text on tax law, Canadian Income Tax Law, including the most recent sixth edition (LexisNexis, 2018).


Benjamin Alarie


14 May 2019
17:00 - 17:55 UTC
55 min