Sept. 21, 2018 – The Treasury Department and Internal Revenue Service have issued a Request for Comments on proposed interim and transition rules (Notice 2018-67) for interpreting they way that nonprofits calculate UBIT payments. The new Section 512(a)(6) of the Internal Revenue Code changes the way nonprofits calculate UBIT; instead of aggregating all of their profits and losses from unrelated business activities, nonprofits must now "silo" their revenues and expenses for each "separate" "trade or business" and pay UBIT on each.