What is the primary factor that triggers UBIT according to its governing principles?

The primary factor that triggers Unrelated Business Income Tax (UBIT) is the engagement in substantial commercial activities that are not substantially related to an organization’s exempt purpose. Non-profit organizations are generally exempt from federal income tax; however, when they generate income through activities that are considered unrelated to their primary mission, they may be subject to UBIT.

The concept behind UBIT is to ensure that tax-exempt entities do not gain an unfair competitive advantage over taxable businesses by participating in business activities unrelated to their charitable or educational goals. The more significant and regular these commercial activities become, the more likely they are to trigger UBIT.

In contrast, the abandonment of non-profit status, the amount of income generated, or the type of business conducted may not inherently trigger UBIT. For instance, an organization may conduct a type of business that is related to its purpose and may not incur UBIT despite generating significant income, so these factors are secondary to the core issue of engaging in substantial commercial activities.