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Buenavista Community Foundation, a non-stock charitable educational organization, is recognized as tax-exempt under Philippine law. It operates two activities on its campus: (i) Exempt activity — a scholarship program and tutoring services for underprivileged students; 70% of its receipts come from this exempt activity; (ii) Campus facility operation — a hotel and conference center on campus that is leased to external guests for accommodation and events; 30% of total receipts come from this non-exempt activity. The Bureau of Internal Revenue has issued a preliminary position that the hotel income is unrelated business income.   (a)Is the hotel income exempt, given the Foundation’s exempt purposes? (b)Can Buenavista Community Foundation maintain its tax-exempt status if it continues to operate the hotel and lease the campus facility to outsiders? (c)What steps should the Foundation take to preserve its exemption for the exempt activities while addressing the hotel income?