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Mike Thrift

Marketing Manager

Section 277 and 501(c)(7): Member vs. Nonmember Income for Social Clubs

Section 501(c)(7) social clubs must keep nonmember income under 35% of gross receipts and nonmember facility use under 15%, while Section 277 quarantines member-side losses for nonexempt membership organizations. This guide walks through how the two rules interact, how to allocate UBTI expenses on Form 990-T, and how to structure a chart of accounts so the member/nonmember split survives an IRS examination.

Section 467 Rental Agreements: Stepped, Prepaid, and Deferred Rent Under the Tax Code's Anti-Abuse Rule

Section 467 forces accrual accounting and imputed interest on commercial leases over $250,000 with stepped, prepaid, or deferred rent — overriding cash-basis treatment, recharacterizing part of every rent payment as a deemed loan between landlord and tenant, and creating Schedule M-1 book-tax differences from ASC 842 straight-line rent.