A common investment structure presented to domestic tax-exempt entities involves investing in flow-through operating businesses through a “blocker corporation.” Avoiding unrelated business taxable income (“UBTI”) is a key focus for many tax-exempt entities. By investing through a blocker corporation, the blocker corporation pays any applicable income tax and then passes on the remaining profits to the tax-exempt entity as a dividend. Corporate dividends are considered passive income and as such, are not subject to the UBIT tax, except in limited…