... describes and analyzes the tax treatment of income and deductions attributable to debt-financed assets owned by exempt organizations. Notwithstanding their general exemption from income taxation, exempt organizations are nevertheless subject to the unrelated business income tax, which taxes income from a regularly conducted trade or business that is unrelated to an organization's exempt purpose or function. Most passive investment income, such as dividends, interest, and rents, is excepted from the scope of the unrelated business income tax. If, however, investment income is derived from debt-financed property, all or part of the income and deductions with respect to the property must be included in computing unrelated business taxable income. The purpose of the debt-financed property rules is to prevent exempt organizations from unfairly competing with their taxable counterparts in the acquisition of businesses and other investment assets that are debt-financed.