Christopher Swift

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Come On In and Stay Awhile: IRS Expands Safe Harbors for Bond-Financed Property

The Internal Revenue Service recently issued guidance in Rev. Proc. 2016-44 that meaningfully expands the safe harbors pertaining to management contracts affecting bond-financed property such as professional services agreements (e.g., radiology), medical director agreements, on-call agreements, food service agreements and management services agreements. While the new framework offers clarity and increased flexibility for Section 501(c)(3) organizations in … Continue Reading

IRS Issues Final Regulations on Requirements for Charitable Hospital Organizations

On December 29, 2014, Final Regulations providing guidance regarding the requirements for charitable hospital organizations were issued by the Internal Revenue Service (IRS). The ACA, enacted March 23, 2010, added new requirements in Section 501(r) that hospital organizations must satisfy to qualify under Section 501(c)(3). Each 501(c)(3) hospital organization is required to meet four general … Continue Reading

IRS Interim Guidance Creates New Category of Permissible Arrangements

Public Comments Due January 22, 2015 On October 24, 2014, the IRS issued Announcement 2014-67, which “amplifies” Rev. Proc. 97-13 regarding certain management contracts that do not result in private business use. Prior to this Announcement, Rev. Proc. 97-13 provided that a per-unit fee arrangement must not exceed three years and must be terminable, without … Continue Reading
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