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Question
Bluewave Foundation, a non-stock charitable educational organization registered in the Philippines, runs two activities: (i) Exempt Activity — a scholarship program and tutoring services for underprivileged students; 75% of its receipts come from the exempt activity; (ii) For-profit subsidiary — Bluewave Data Systems, Inc., wholly owned by the Foundation, which provides contracted IT training and software development to external clients; 25% of receipts come from the subsidiary. The Bureau of Internal Revenue has issued a preliminary position that the subsidiary's income is unrelated business income. (a) Is the subsidiary income exempt, given the Foundation's exempt purposes? (b) Can Bluewave Foundation maintain its tax-exempt status if it continues to operate the subsidiary? (c) What steps should Bluewave Foundation take to preserve its exemption for the exempt activities while addressing the subsidiary's income?