A related organization's assets and income count as the school's
What the document says“assets and net investment income of any related organization with respect to an educational institution shall be treated as assets and net investment income, respectively, of the educational institution, except that--”
The section treats a related organization's assets and net investment income as the institution's, except that no amount counts for more than one institution, and that unless the organization is controlled by the institution or is described in section 509(a)(3) with respect to it, assets and income not intended or available for the institution's use or benefit do not count. A related organization is one that controls or is controlled by the institution, is controlled by persons who also control it, or is a supported organization or an organization described in section 509(a)(3) with respect to it. The Secretary must prescribe rules to stop the tax being avoided, including through restructuring endowment funds.
What the document actually says“assets and net investment income of any related organization with respect to an educational institution shall be treated as assets and net investment income, respectively, of the educational institution, except that--”
A linked body's assets and income count as the school's. Two carve-outs follow.
No sum may be counted for two schools. Money not meant for the school does not count. That second carve-out has its own limits.
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