With the hope of clarifying a difficult issue, this paper examines the traditional categories of exempt organizations (EOs), rationales for their exempt status, tests for gaining and maintaining their exempt status, standard tests used to impose unrelated business income tax (UBIT), and ways in which the traditional tests and standards are changing. Furthermore, this paper predicts areas of future change, discusses ways in which EOs can immediately strengthen their exempt status to avoid unnecessary UBIT, and suggests principled arguments which can be used to halt additional unwarranted incursions by tax "reformers" and "simplifiers."

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