22 | P a g e
Unrelated Business Income Tax
If the PTA’s sole source of labor for all fundraising events is volunteers, the PTA will have no
unrelated business income and this section can be disregarded.
If, however, a PTA ever pays anyone for services to assist it in a fundraising event, this section
should be reviewed carefully.
As a tax exempt organization, PTA revenues are not subject to federal income tax if the revenue is
raised in a manner that is related to the PTA’s tax exempt purpose. However, it is possible for some
revenue to be subject to income taxation. When this occurs, the amount subject to taxation falls
into the category of “unrelated business income”.
A transaction or activity generally will be classified as yielding unrelated business income if it has all
of the following three properties.
1. The activity provides income (but does not necessarily produce a profit) and the PTA takes
an active role in the generation of the income.
2. The activity is conducted on a regular and continuous basis.
3. The activity is a fundraising activity that is unrelated to the mission of the PTA.
Even if the proceeds are used to further the purposes of PTA, if the method of raising the funds is
not related to the purposes of PTA, the revenue is deemed to be unrelated business income. In
other words, fundraising is not a related activity just because the net revenue is used to support PTA
programs.
However, if the activity is conducted by the PTA and at least 85% of the labor is provided by PTA
volunteers, the income is generally excluded from taxation (even if the three conditions above
exist).
If the PTA’s unrelated activity starts to rival its related activity (so that the unrelated activity is
perceived to be dominant) the PTA may no longer be perceived as a charitable organization
supporting itself with some unrelated business income. The IRS may, instead, view the PTA as a
business with some charitable activities. At that point, the PTA would lose its tax exempt status.
Also, IRS regulations require non-profit organizations to report unrelated business activities when
gross receipts are at least $1,000. The IRS requires to report and pay taxes on such gains by filing
IRS Form 990-T. At this point, it may be best to solicit professional advice on filing any and all IRS
forms.
Disclosure Statements
PTAs are required by the IRS to disclose rules to inform prospective donors about the extent to
which their contributions are legally tax deductible.