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Question
Kalayaan Foundation, a non-stock charitable educational organization, is recognized as tax-exempt in the Philippines. It runs two activities: (i) Exempt activity — a rural education program that includes scholarships and teacher training; 68% of its gross receipts come from this exempt activity; (ii) For-profit subsidiary — Kalayaan Analytics, Inc., a wholly owned subsidiary that provides data analytics and market research services to external clients; 32% of gross receipts come from the subsidiary. For the current year, 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 Kalayaan Foundation maintain its tax-exempt status if it continues to operate Kalayaan Analytics? (c)What steps should Kalayaan Foundation take to preserve its exemption for the exempt activities while addressing the subsidiary's income?