Unrelated Business Income and Form 990-T

Guide · Last reviewed October 20, 2026 · Legal and tax review: pending

Exempt does not mean every dollar is free of tax. Income from a business that is regularly carried on and not substantially related to the organization’s exempt purpose can be taxed, and may have to be reported on Form 990-T. This page explains the idea and the filing rules. Facts come from the IRS page on unrelated business income tax and the Form 990-T instructions (2025).

The three-part test

Income is unrelated business income when it comes from:

  1. a trade or business,
  2. that is regularly carried on, and
  3. that is not substantially related to the organization’s exempt purpose.

The tax applies to the net income after the expenses of earning it. Special rules apply to certain organizations under sections 501(c)(7), (9), (17) and (20).

When Form 990-T is required

Situations that raise the question

ActivityWhy it may be unrelated business income
Sponsorships and advertising in a newsletter, program book or websiteThe line between a simple thank-you and advertising matters. Review the arrangement before you sign.
Renting space or equipmentRent from real property is often excluded, but not always (for example if the property is debt-financed, or services are provided).
Selling merchandise unrelated to the missionA gift shop that sells items with no link to the exempt purpose may be a regular unrelated business.
Events and food or drink salesFrequency, who does the work and whether it supports the mission all matter.
Investment incomeDividends, interest and many capital gains are generally excluded, but income from debt-financed property or some partnership interests may not be.

Some exclusions exist, such as for businesses run mainly by volunteers or selling donated goods. Whether one applies depends on the facts, so read the instructions or ask us.

Keep the books readyTo report this income correctly, the books must separate the activity’s revenue and direct expenses, and show how shared costs are allocated. Many organizations only find out they have unrelated business income when a volunteer mentions a new revenue idea or an IRS letter arrives.

General educational information. Filing rules, thresholds, penalties and state requirements depend on individual facts and change over time. Confirm them on irs.gov and with your state regulators, and consult a qualified professional before filing a return or an application. This site is an independent guide and is not affiliated with the IRS.