UBIT is a tax that Congress added to the tax code in 1950. Its intent was to level the playing field between tax-exempt entities and regular tax-paying businesses. Too many tax-exempt entities were operating as fully functioning businesses without paying any taxes because of their special status. Congress, viewing this as an unfair advantage over taxpaying competitors, created a means to tax tax-exempt entities that operated businesses outside the scope of their original purpose. Eventually, IRAs were added into the mix of tax-exempt entities that would be taxed on income earned from activities that were deemed to be not related to their primary function of prividing assets to provide funds for an individual’s retirement.