To: University Business Managers
From: Dennis Press, Assistant Vice Chancellor and University Controller
Date: July 2, 2013
The Financial Reporting Department of the University Controller’s Office is responsible for compiling unrelated business income (UBI) revenue and expenses each fiscal year for inclusion on the University’s Form 990‐T filed annually with the Internal Revenue Service.
Unrelated business income may be generated if goods or services are sold to external customers that are not part of the university campus, i.e., students, faculty, staff, and other University departments. When an activity is conducted with external non-University customers, the department conducting the activity is required to complete the UBI Tax Compliance Questionnaire. This questionnaire is the primary tool used by the Financial Reporting Department in determining the taxable status of the activity – whether the net income generated should be reported as unrelated business income.
Revenues generated from sales to external non-University customers may generate unrelated taxable income when the activity constitutes a regularly carried on trade or business that is not substantially related to the University’s educational mission. To determine “relatedness,” the Internal Revenue Code focuses on the nature of the activity. A university unit or department is not prohibited from engaging in activities which are determined to generate unrelated business income, but is required to report net operating results, fiscal year revenue and expenses, for an unrelated business activity to the Financial Reporting Department. The University policy regarding UBI can be found in the Finance Division Policies and Procedures Manual, Policy 712.
Please complete a separate questionnaire for each income‐producing activity conducted by the department where external non-University customers are involved and return the completed questionnaire to David Blakemore, Director of Financial Reporting, either by campus mailbox 1270 or by email at blakemor@email.unc.edu. If you have any questions, please call 919-962-1362 or contact the email address noted above.
Note: This memo is also being sent to Deans, Directors and Department Chairs.