FROM THE OFFICE OF PUBLIC AFFAIRS
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December 1, 2004
JS-2120
Treasury and IRS Issue Guidance on Trade Show Activities
The Treasury Department and the IRS issued guidance today on the tax treatment of Internet activities conducted by a trade association in conjunction with a trade show.
The revenue ruling extends the current-law exception from the definition of unrelated trade or business for "qualified convention and trade show activity" to Internet activities that are ancillary to a convention, annual meeting or trade show. A "convention, annual meeting, or trade show" is a specific event at which individuals representing a particular industry and members of the public gather in person at one location during a certain period of time.
The ruling concludes that making the same information that is available at a trade show available on the Internet, during approximately the same time period as the trade show itself, is a "qualified convention and trade show activity." Making the same information available on the Internet enhances and augments the trade show by allowing interested persons to preview the show before attending and follow up on information gathered at the show. The ruling also concludes that Internet activities that are not ancillary to a convention, annual meeting, or trade show do not qualify for the statutory exception for conventions, annual meetings, and trade shows.
"The Internet is a valuable tool that organizations can use to supplement their trade shows by making available in a different medium the same information that is available at the event," said Treasury Acting Assistant Secretary Greg Jenner. "The UBIT exception for qualified trade shows is narrow, but this guidance makes clear that ancillary Internet activities fall within the exception."
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