The IRS and Treasury Department recently released new guidance for calculating the tax on unrelated business income (“UBI”) activities of tax-exempt organizations with more than one UBI activity. With the passage of the 2017 Tax Cuts and Jobs Act (the “Tax Act”), exempt organizations are required to calculate UBI tax separately for each UBI activity for taxable years beginning after December 31, 2017. Under prior law, exempt organizations could use the losses from one UBI activity to offset income from another.