[1] https://www.irs.gov/charities-non-profits/unrelated-business...
> Once the transaction is completed, PIR will continue to meet the highest standards of public transparency, accountability, and social performance in line with its longstanding purpose-driven mission, and will consider seeking B Corporation certification.
I guess they intend to abandon their non-profit status soon?
This is not the same as the organization can never end the year with more money in the bank than it started. This is not counted as profit, it's simply money that must eventually be spent for charitable purposes in later years.
Large amounts of money can enter the organization, but it can never end exit. (Though, there are some loopholes, like admistator salaries)
[1] https://www.hurwitassociates.com/taxation-of-unrelated-busin...
1. It is trade or business - sure, it's trade as in sale, so that matches.
2. It is regularly carried on - not really, there's only one .org domain so one can't regularly sell it.
3. It is not substantially related to furthering the exempt purpose of the organization - that one would be the toughest to prove, the purpose of the organization is "to promote the open development, evolution and use of the Internet for the benefit of all people throughout the world". Of course you can think that selling .org to a particular company may not benefit the world, but surely it's just your opinion, you can't prove that it has no relation to the original mission.
Also, using taxation as a tool in policy disagreements is a really bad idea. It is tempting to say "ah, so do this bad thing so we retaliate against you by attacking your tax status" but that's not what tax status is for. If it's a non-profit, it remains a non-profit even after it does bad thing, and whether it is a non-profit or not should not depend on whether we like what they're doing. Tax status is not a form of punishment or reward, at least it shouldn't be.
You're right. I misread #2 as the inverse so misunderstood what UBI was.
> 3. It is not substantially related to furthering the exempt purpose of the organization - that one would be the toughest to prove...
Kinda a moot point given #2, but the IRS elaborates (emphasis mine), "... only when the conduct of the business activities has causal relationship to achieving exempt purposes (_other than through the production of income_)"