Summary

Reorganizes parts of the tax code and changes how interest is counted when figuring unrelated business taxable income for tax‑exempt organizations. This could raise or lower tax owed by nonprofits that run unrelated businesses. Also allows the Secretary to purchase SIFIA bonds that cannot be sold, using procedures and credit standards similar to the TIFIA loan program. An effective date is set for when these tax and financing changes begin to apply.

Key Points

• Creates new tax-code subparts and makes clerical updates.
• Changes how interest is counted when calculating UBTI for tax‑exempt entities.
• Authorizes the Secretary to buy SIFIA bonds that cannot be sold.
• Requires TIFIA‑like procedures and credit standards for any SIFIA bond purchases.
• Establishes an effective date for both the tax and financing provisions.
• Nonprofits with unrelated business activities may see their UBTI rise or fall depending on their financing structure.
• Provides a federal backstop that can improve liquidity and reduce financing risk for SIFIA bond issuers.
• Authorizes, rather than appropriates, the bond‑purchase activity; separate funding decisions may still be needed.

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