Contents

SPECIAL EVENTS AND CORPORATE SPONSORSHIPSThe corporate sponsorship rules are, as noted, formulated as a safe-harborbody of law. Thus, if the terms and conditions of these rules cannot be satisfied,the opportunity nonetheless remains for application of other rules that maycause a corporate sponsorship payment not to be treated as unrelated businessincome. These other rules might include use of the exclusion for royalties, 47 orthe exception for activities substantially all the work for which is performed byvolunteers, 48 or the exception for activities not regularly carried on. 4947 See § 3.4(g).48 See § 3.4(f).49 See § 3.4(c). For further reading about corporate sponsorship payments, see Appendix L. 626