Ezel / IRS Rulings / 200947041

CCA 200947041: Unrelated-business-income exception for short-term security loans

Number
200947041
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Exception, Additions, and Limitations on Unrelated Income
Topics
Tax-exempt organizations
Code sections
§ 512, § 6110
Publicly released
November 20, 2009
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2009, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2009
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

This Chief Counsel advice states that, as a general matter, an exemption from unrelated business income applies to short-term security loans under § 512(a)(5). The writer notes limited personal experience with the issue and refers the recipient to a redacted attorney for further explanation.

Ruling snapshot

  • Question: Is there an unrelated-business-income exception for short-term security loans?
  • Outcome: Advice given
  • Key authorities: IRC § 512(a)(5)

Full text (IRS public release)

ID: CCA_2009100610070957 Number: 200947041
Release Date: 11/20/2009
Office: ----------------------------
UILC: 512.01-00

From: ---------------
Sent: Tuesday, October 06, 2009 10:07:16 AM
To: --------------------------------------------------------------------------------
Cc: ---------------------
Subject: RE: MAP Question ---------

------- as a general matter there is an exemption from UBI for short term security loans that is described in
512(a)(5). However, since this is not a matter I have much experience with if you wish to get a better
understanding of how the exemption works you can call ----------------------------------------who is an attorney
in -------------------.

-------

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