On December 4, 2020, the IRS released a new private ruling (PLR 202049002), holding that a physician-owned medical services professional corporation (PC) could be included in a consolidated tax return filing along with the...more
In the past few years, the IRS has changed its guidance on whether “management contracts” result in private business use for purposes of the restrictions on use of property financed with tax-exempt bonds. This update...more
5/8/2018
/ Borrowers ,
Compensation ,
Hospitals ,
Internal Revenue Code (IRC) ,
IRS ,
Management Contracts ,
New Guidance ,
New Rules ,
Physicians ,
Public Private Partnerships (P3s) ,
Revenue Procedures ,
Safe Harbors ,
Service Contracts ,
Tax-Exempt Bonds
On December 9, 2016, the Department of the Treasury and Internal Revenue Service (IRS) published final regulations on the definition of “issue price,” for purposes of the arbitrage rules that apply to tax-exempt bonds....more
On August 22, 2016, the Internal Revenue Service (IRS) released Rev. Proc. 2016-44, which provides new guidance on the treatment of “management contracts” for purposes of the restrictions on use of property financed with...more
On October 27, 2015 the U.S. Treasury Department and Internal Revenue Service published final regulations concerning the treatment of “mixed-use” projects financed with tax-exempt bonds. These new regulations have particular...more
On October 27, 2015 the U.S. Treasury Department and Internal Revenue Service published final regulations concerning the treatment of “mixed-use” projects financed with tax-exempt bonds. These new regulations have significant...more
10/28/2015
/ 501(c)(3) ,
Borrowers ,
Carve Out Provisions ,
Final Rules ,
Government Bonds ,
Internal Revenue Code (IRC) ,
IRS ,
Mixed-Use Zoning ,
Public Private Partnerships (P3s) ,
Recordkeeping Requirements ,
Remedial Actions ,
Safe Harbors ,
State and Local Government ,
Tax Exempt Entities ,
Tax Planning ,
Tax-Exempt Bonds ,
U.S. Treasury
On October 24, 2014, the IRS released Notice 2014-67, which establishes more favorable safe harbors for types of service contracts and other arrangements using property financed with tax-exempt bonds. The Notice also provides...more