HE TAX CUTS AND JOBS ACT added new IRC §274 (a) (4), which generally disallows the deduction for the expense of any "qualified transportation fringe" (QTF) provided to an employee of the taxpayer. Congress also tried to provide a similar result for tax-exempt organizations, where the disallowed deduction might otherwise not matter. New IRC §512(a) (7) generally provides that a tax-exempt organization's unrelated business taxable income (UBTI) is increased by the amount of the QTF expense that's disallowed under IRC §274.
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