Tag Archives: IRS

Preparing for the New Partnership Audit Rules

By John R. Lehrer II and Heather K. P. Fincher on September 28, 2017 Posted in Uncategorized

The Bipartisan Budget Act of 2015 substantially changed audit-related rules impacting entities taxed as partnerships, including both state-law partnerships and many limited liability companies (LLCs). The most significant change is that any additional tax or penalties resulting from an audit of an entity taxed as a partnership generally will be assessed and collected at the … Continue Reading

IRC Section 501(r): An ACA Provision That’s Likely Here to Stay

By Laurice Rutledge Lambert and Elizabeth O’Connell on December 23, 2016 Posted in Uncategorized

For tax-exempt hospitals, the Section 501(r) Internal Revenue Code (IRC) requirements of the Affordable Care Act are “old news” by now. However, despite the recent focus on repeal of the ACA, it is worth noting that this provision is likely here to stay. Sen. Charles Grassley (R-IA), a long-time advocate for low-income, uninsured, and underinsured … Continue Reading

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

By Katy Appleby, Emily Crosby and Christopher Swift on October 17, 2016 Posted in Uncategorized

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

By Christopher Swift on January 22, 2015 Posted in Uncategorized

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

By Christopher Swift on January 16, 2015 Posted in Uncategorized

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

Employer Shared Responsibility Final Regulations Offer Partial Temporary Enforcement Relief

By John W. Boyd and Susan Whittaker Hughes on February 11, 2014 Posted in Uncategorized

Editor’s Note: This post originally appeared in BakerHostetler’s Health Care Reform executive alert. Enforcement of the employer shared responsibility provisions of the Affordable Care Act (ACA) has been further delayed for employers with between 50 and 99 full-time equivalent employees and temporarily eased for employers with 100 or more full-time equivalent employees. The relief was announced on February … Continue Reading