图书简介

Preface ix About the Authors xi Book Citations xv 1 Tax-Exempt Healthcare Organizations: An Overview 1 1.2 Defining Tax-Exempt Organizations 1 1.5 Charitable Healthcare Organizations 1 1.8 Promotion of Health 2 1.10 ABLE Programs 2 3 Public Charities and Private Foundations (New) 5 3.3 Commerciality Doctrine 5 4 Private Inurement, Private Benefit, and Excess Benefit Transactions 9 4.4 Private Inurement-Scope and Types 9 4.6 Essence of Private Benefit 10 4.9 Excess Benefit Transactions 12 5 Public Charities and Private Foundations 13 5.1 Public Institutions 13 5.6 Recognition of Change in Public Charity Status 13 7 Lobbying and Political Activities 15 7.1 Legislative Activities Limitation 15 7.4 Political Activities Limitation 16 7.5 Business Expense Deduction Rules and Political Activities 18 7.7 Public Policy Advocacy Activities 19 7.8 Political Activities of Social Welfare Organizations 19 8 Hospitals 21 8.3 Public Hospitals 21 9 Managed Care Organizations 23 9.3 Commercial-Type Insurance Providers 23 9.5 Recent Developments 23 13 Other Provider and Supplier Organizations 27 13.3 Qualified Nonprofit Health Insurance Issuers 27 13.5 Accountable Care Organizations 28 16 For-Profit Subsidiaries 33 16.3 Attribution of Subsidiary’s Activities to Exempt Parent 33 17 Exempt and Nonexempt Cooperatives 35 17.1 Cooperative Hospital Service Organizations 35 18 Business Leagues 37 18.1 Business Leagues in General 37 18.2 Healthcare Trade Associations 38 19 Other Health-Related Organizations 39 19.4 Hospital Management Services Organizations 39 19.5 Regional Health Information Organizations 40 20 Healthcare Provider Reorganizations 41 20.1 Some Basics about Reorganizations 41 21 Mergers and Conversions 43 21.4 Conversion from Nonexempt to Exempt Status 43 22 Partnerships and Joint Ventures (New) 45 22.9 Whole-Hospital Joint Ventures 45 24 Tax Treatment of Unrelated Business Activities 47 24.2 Definition of Trade or Business 47 24.3 Definition of Regularly Carried On 49 24.5 Application of Substantially Related Test to Healthcare Organizations 50 24.11 Pharmacy, Medical Supplies, and Service Sales 51 24.12 Laboratory Testing Services 51 24.13 Medical Research 52 24.18 Other Exceptions to Unrelated Income Taxation 53 24.20 Revenue from Controlled Organizations 55 24.21 Unrelated Debt-Financed Income 55 24.23 Computation of Unrelated Business Taxable Income 55 25 Physician Recruitment and Retention 61 25.5 Specific Recruitment and Retention Techniques 61 26 Charity Care 63 26.6 Definitional and Reporting Issues 63 26.9 Charity Care and National Health Reform 64 26.10 Additional Statutory Requirements for Hospitals 64 26.12 Provider Taxes (New) 82 27 Worker Classification and Employment Taxes 85 27.7 Medical Residents and the Student Exception 85 28 Compensation and Employee Benefits 87 28.3 Executive Compensation 87 28.5 Overview of Employee Benefits Law 87 28.6 Deferred Compensation in General 88 28.7 Excessive Executive Compensation (New) 91 30 Tax-Exempt Bond Financing 95 30.3 Disqualification of Tax-Exempt Bonds 95 31 Fundraising Regulation 105 31.2 Federal Law Regulation 105 33 Governance 107 33.4A IRS Ruling Policy 107 34 Exemption and Public Charity Recognition Processes 111 34.1 Exemption Recognition Process 111 34.5 Public Charity Status 121 34.6 Group Exemption 121 34.7A Notice Requirements for Social Welfare Organizations (New) 122 34.8 Procedure Where Determination Is Adverse 123 34.9 Constitutional Law Aspects of Process 125 35 Maintenance of Tax-Exempt Status and Avoidance of Penalties 127 35.1 Material Changes 127 35.2A Modification of Tax Exemption (New) 129 35.4 Redesigned Annual Information Return 129 35.5 Disclosure Requirements 130 35.6 IRS Disclosure to State Officials 131 36 IRS Audits of Healthcare Organizations 133 36.2 Audit Procedures 133 Cumulative Table of Cases 139 Cumulative Table of IRS Revenue Rulings 149 Cumulative Table of IRS Revenue Procedures 153 Cumulative Table of IRS Private Letter Rulings 155 Cumulative Table of IRS Technical Advice Memoranda 161 Table of Chief Counsel Advice Memoranda 163 Cumulative Table of IRS General Counsel Memoranda 165 Table of Tax Reform Legislation 167 Cumulative Index 173

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