Tax General Business Health

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North Carolina General Assembly Week in Review

The Senate budget process continued this week, though at a slower pace than members had planned for in the schedule released last month. Budget votes originally scheduled for Wednesday and Thursday of this week were delayed...more

TDADS denying HCSSA License Renewals because of Tax Liens

In July 2012, the U.S. Government Accountability Office published a Report entitled "Providers in Three States with Unpaid Federal Taxes Received over $6 Billion in Medicaid Reimbursements" (the "Report"). ...more

IRS Finalizes Revenue Procedure on 501(r) Corrective Measures

On March 10, 2015, the Internal Revenue Service (IRS) released Revenue Procedure 2015-21 (Revenue Procedure), which will be officially published on March 30, 2015, in Internal Revenue Bulletin 2015-13. The Revenue Procedure...more

IRS Issues Private Letter Ruling on Treatment of Managed Professional Corporations

The Internal Revenue Service (“IRS”) recently published a private letter ruling (“PLR”) that permits a practice management corporation to include two managed professional corporations as members of the management...more

IRS Private Letter Ruling Provides Tax Planning Opportunities for Healthcare Companies

The IRS recently issued PLR 201451009, providing that a management services company and two professional corporations (PCs) were members of the same affiliated group under Section 1504(a) of the Internal Revenue Code...more

Accountant and Attorney Liability Newsbrief - Winter 2015

In This Issue: - The Affordable Care Act and CPAs: It Takes a Village - U.S. District Court for District of Massachusetts Holds Testator’s Attorney Can Be Held Liable to A Beneficiary - New Jersey...more

Implications of Final Regulations Under Internal Revenue Code Section 501(r)

The Internal Revenue Service replaced proposed regulations under Section 501(r) of the Internal Revenue Code (the “Code”) with final regulations in late 2014 (the “Final Regulations”). As enacted in the Patient Protection and...more

"Congressional Investigations Highlight Risks for Companies Across Industries"

An examination of congressional investigations in 2014 reminds us that such investigations can strike an industry or company at any time. Irrespective of the subjects, the investigations typically share one or more of the...more

For-Profit Hospitals and Management Companies May Enjoy New Tax Benefits

The IRS recently issued a private letter ruling which allowed a for-profit medical group (e.g., a hospital) to benefit from losses sustained by its wholly owned physician medical group – and allowed this to occur in a state...more

IRS Interim Guidance Creates New Category of Permissible Arrangements

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...more

UK Legal HIghlights 2014 And Beyond

Welcome to our 2014 edition of UK Legal Highlights. This publication is a reminder of some of the most important and significant developments DLA Piper reported in 2014, along with some forthcoming developments to look out...more

Ancillary Joint Ventures Involving Taxable and Tax-Exempt Health Care Entities: Addressing the Chilling Effect of IRS Inaction

Tax-exempt health care systems facing growing operating costs and falling revenues frequently explore creation of ancillary joint ventures (AJVs) as vehicles to raise capital, share risk, expand coverage, and provide care...more

IRS provides interim guidance for ACO participation in Medicare Shared Savings Programs and expands safe harbors for management...

On October 24, 2014, the IRS published Notice 2014-67, which expands the Revenue Procedure 97-13 safe harbors regarding management contracts and further provides interim guidance related to a health care organization’s...more

ACO Participation By Tax-Exempt Healthcare Organizations – Is Tax-Exempt Financing at Stake?

Does A Tax-Exempt Healthcare Organization’s Participation in an Accountable Care Organization (ACO) Adversely Affect Its Tax-Exempt Financing? IRS Notice 2014-67 Provides Guidance....more

The Medical Device Tax in the Wake of 2014 Midterm Elections

Repeal of the medical device tax has seen frequent news coverage since the tax’s enactment in 2010 as part of the Affordable Care Act. The tax, which went into effect in January, 2013, imposes a 2.3% sales tax on a range of...more

IRS Provides Increased Flexibility on Management Contracts for Tax-Exempt Bond-Financed Property

On October 24, 2014, the Internal Revenue Service issued Notice 2014-67 (the “Notice”), which provides important guidance and increased flexibility for issuers and conduit borrowers of tax-exempt bonds regarding contracting...more

IRS Releases Guidance on Private Business Use, and ACOs and Management Contracts

On October 25, 2014, the Internal Revenue Service (the IRS) released Notice 2014-67 that provides interim guidance on (i) participation in the Medicare Shared Savings Program through an accountable care organization (ACO) and...more

IRS Releases Private Business Use Guidelines for ACO Participants

On Friday, October 24, 2014, the Internal Revenue Service (IRS) released Notice 2014-67, providing guidance regarding the circumstances under which participation by a hospital in an Accountable Care Organization (ACO) will...more

Sale-leasebacks accommodate buyer and seller in today’s healthcare real estate market: 7 reasons why they work, 5 pitfalls to note

For many years, low interest rates allowed companies with strong credit ratings to obtain access to cheap capital through traditional financing methods – meaning there was little enthusiasm for sale-leaseback...more

MoFo New York Tax Insights - Volume 5, Issue 9 - September 2014

In This Issue: - ALJ Upholds Denial of Sales Tax Refund Because Vendor Failed to First Make Refunds to Customers - HMO Held Exempt from New York City General Corporation Tax - State Tax Department Issues...more

First Circuit Rejects Talley and Allows a Business Expense Deduction for Settlement Payments Made Under the False Claims Act

On August 13, 2014, the United States Circuit Court for the First Circuit rejected the United States’ request to deny Fresenius Medical Care Holdings Inc. from deducting a portion of a settlement payment to settle civil...more

Hobby Lobby ripples still being measured

How can the controversial decision in the Hobby Lobby contraception coverage case impact employers? The U.S. Supreme Court in June decided the controversial case of Burwell v. Hobby Lobby Stores Inc. The court ruled...more

Captive Insurance: Feds Promote Tax Benefits, but Pay Attention to the Details

Recent IRS rulings and a U.S. Tax Court decision continue to lay a solid foundation for captive insurance companies. However, the tax requirements must be strictly followed. Below we provide an update to assist captives in...more

Favorable Ruling: Taxability of HMOs Under New York City General Corporation Tax

A New York City Tax Appeals Tribunal Administrative Law Judge (ALJ) recently ruled in favor of Aetna, Inc. (Aetna) on whether a health maintenance organization (HMO) was “doing an insurance business” in New York State,...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 23: The Impact of Employment Contract Terms on Variable Hour...

For applicable large employers (i.e., employers who employed at least 50 full-time and full-time equivalent employees on business days during the preceding calendar year) endeavoring to comply with the Affordable Care Act’s...more

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