[Foundation-l] WMF seeking to sub-lease office space?

[Anthony]

On Fri, Sep 4, 2009 at 9:51 PM, Gregory Kohs <thekohser at gmail.com> wrote:
>
> A little bird suggested I ask if the Foundation will be filing a Form
> 990-T once it finds a tenant, as it would be a business activity over
> $1,000 unrelated to a non-profit mission and would thus possibly
> trigger IRS rules regarding Unrelated Business Income Tax (which are
> rather strict).  Among other things, the 990-T is a public form, so it
> would force the Foundation to disclose further information on its
> operations.
>

Ah Greg Greg Greg.  You should have run this one past me first.  Rents
generally are not subject to UBIT.  This is not, however, a reliance
opinion, and can't be used to avoid penalties.