President Trump's signature legislative achievement, the Tax Cuts and Jobs Act (the "Act"), brought the most sweeping change to U.S. tax law since 1986. The Act includes many changes that may impact the way tax-exempt organizations operate. Specifically, the Act, modifies the way unrelated business income is calculated and imposes limitations on net operating losses (“NOLs”). Such changes have the potential to put tax-exempt organizations, including qualified retirement plans, at a disadvantage relative to for-profit organizations and may ultimately drive changes to the way qualified plans operate. Sponsors of qualified retirement plans and other exempt organizations should carefully review their investments to determine the potential tax and administrative burdens of these changes and whether any mitigation strategies are available.

Alvarez & Marsal's Compensation & Benefits team is available to discuss any questions that you may have to help mitigate your UBIT liability arising from these changes. Please feel free to contact us for additional information.