In the event an organization to which section 511 applies is a member of a partnership regularly engaged in a trade or business which
is an unrelated trade or business with respect to such organization, the organization
shall include in computing its unrelated business taxable income so much of its share
(whether or not distributed) of the partnership gross income as is derived from that
unrelated business and its share of the deductions attributable thereto. For this purpose, both the gross income and the deductions shall be computed with
the necessary adjustments for the exceptions, additions, and limitations referred
to in section 512(b) and in § 1.512(b)–1. For example, if an exempt educational institution is a partner in a partnership
which operates a factory and if such partnership also holds stock in a corporation,
the exempt organization shall include in computing its unrelated business taxable
income its share of the gross income from the operation of the factory, but not its
share of any dividends received by the partnership from the corporation. If the taxable year of the organization differs from that of the partnership, the
amounts included or deducted in computing unrelated business taxable income shall
be based upon the income and deductions of the partnership for each taxable year of
the partnership ending within or with the taxable year of the organization.
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