In analyzing whether a link or banner exchange
with another entity is subject to UBIT, the IRS looks to the purpose of the exchange, and whether it is an exchange of advertising, or merely an attempt to refer the site visitor to additional information in furtherance of the organization's exempt purposes and activities.
For these reasons it's much better to use a banner exchange scheme than try to do it yourself.
Banner exchange schemes such as those offered by Microsoft and many Internet Service Providers (ISPs) are an excellent place to start.
Joining a banner exchange program is another way to attract customers and make money.
The first free banner exchange network that lets you include sound effects with your banner ad--no plug-ins required.
From 17 April the site will also provide a web site creation service called Sitebuilder and a banner exchange
service that will enable small companies to place banner adverts on other web sites for free in return for placing banners from other web sources on their own site.
There are free or very inexpensive web sites, free and low-cost ad sites, free banner exchange
programs, free web ring programs, free newsgroups (the appropriate ones) to post in and make contacts, and free search engines and link directories to be listed in.
I have spent many hours trying free banner exchanges
, low budget promotional offers, link strategies, and yes, I even tried bulk e-mail, only to realize I hadn't spent the time to make my site appealing enough to hold anyone's interest," says Kevin Frazier, VP/COO of Focus on U (www.focusonu.com).