Emphasis on Unrelated Business Income Tax Enforcement Should Be Enhanced.

The Commissioner, TE/GE Division, should clarify the EO Examination function's guidance to require examiners to address UBI and include evidence of its UBI identification efforts in every case file, including focused examinations.

The Commissioner, TE/GE Division, should restore UBI references to the IRM to reinforce their importance to an organization's exempt status.

The Commissioner, TE/GE Division, should require, in appropriate cases, that examiners request any missing Forms 990-T and inform taxpayers of the potential risks if they do not comply with their filing requirements in accordance with Treasury Regulation Section 1.6012-2(e).

The Commissioner, TE/GE Division, should evaluate claim thresholds sent to the field in an effort to minimize impact on limited resources and analyze specific case circumstances to prevent unnecessary case referrals to an EO Examination group.

The Commissioner, TE/GE Division, should include UBI tax issues in future compliance projects to identify issues preventing taxpayers from being compliant with their UBI reporting requirements.