AHLA: Tax Issues for Healthcare Organizations. Tax-Exempt Bonds, Schedule K and Preparing for IRS Private Business Use Examinations
|
|
- Erica Walton
- 6 years ago
- Views:
Transcription
1 AHLA: Tax Issues for Healthcare Organizations Tax-Exempt Bonds, Schedule K and Preparing for IRS Private Business Use Examinations October 15-16, 2012 Now, tell me exactly how you got these Schedule K numbers? 2 1
2 Introduction Focus on activities of 501(c)(3) Organizations that borrow on a tax-exempt basis Schedule K Annual Reporting IRS wants to know more information about your Bonds In IRS fiscal year 2010, there were approximately 915 examinations of outstanding tax-exempt debt Schedule K provides the IRS with information as to whether borrowers are satisfying the Federal tax law requirements The IRS recently announced that they will begin auditing Schedule K In the event of an IRS bond audit or a Schedule K audit, it will be necessary for borrowers to provide clear and convincing information to support their Schedule K reporting 3 Table of Contents I. Overview of Private Business Use Rules II IRS Schedule K III. Examples of Private Business Use and How to Measure It 4 2
3 I. Overview of Private Business Use Rules 5 Overview 501(c)(3) Bonds At least 95% of the net proceeds of the bond issue must be used in a manner related to the exempt purposes of the Section 501(c)(3) organization No more than 5% of the net proceeds of the bond issue can be used for a private use or an unrelated trade or business use. For this purpose, costs of issuance of the bonds paid with bond proceeds is treated as a private use 6 3
4 Overview 501(c)(3) Bonds Private Use Use of bond financed property in a trade or business by other than a 501(c)(3) organization or a State or local government Examples: Lease of bond financed space to a for-profit entity for use of a hospital cafeteria Certain management contracts (e.g. contracts with non employee medical professionals) Certain sponsored research contracts 7 Overview 501(c)(3) Bonds Unrelated Trade or Business Use Use of bond financed property by a 501(c)(3) organization in an unrelated trade or business activity Unrelated trade or business use involving bond financed property will generally constitute private use even if it does not give rise to a liability for unrelated business income tax 8 4
5 Private Use Exceptions Management Contract Guidelines IRS Rev. Proc Provides framework for contracts with non-employees/outside providers for various services involving the use of bond financed property Contracts with non-employees Professional corporations Cafeteria operations Outsourcing of certain operations to third parties 9 Private Use Exceptions Research Contract Guidelines Revenue Procedure Permits certain types of research to be conducted within bond financed space without resulting in research sponsor being treated as private user Applies only to basic research any original investigation for the advancement of science not having a commercial objective 10 5
6 Private Use Exceptions Corporate Sponsored Research Any license or other use of resulting technology by the sponsor is permitted only on the same terms the 501(c)(3) organization would permit that use by an unrelated non-sponsored party (i.e., the sponsor must pay a competitive price) The price paid by the sponsor must be determined at the time the license or other resulting technology is available for use The sponsor may have exclusive use of the license or resulting technology 11 Private Use Exceptions Industry or Federally Sponsored Research Agreements A single sponsor or multiple sponsors agree to fund basic research The 501(c)(3) organization determines the research to be performed and the manner in which it is to be performed Title to any patent of product lies exclusively with the 501(c)(3) organization Sponsor(s) get nothing more than a non exclusive right to use product of that research 12 6
7 Private Use Exceptions Research Contracts Federal Government Rights Under the Bayh-Dole Act The rights of the federal government mandated by the Bayh-Dole Act will not cause a research agreement to fail the safe harbor 13 Private Use Exceptions Incidental Contracts or Arrangements Small physical use of space ATM, kiosks, vending machines, laundry facilities Cannot exceed 2.5% of proceeds or space of facility Contract for services supporting organization activities Janitorial services Equipment repair Billing activities or similar services 14 7
8 II IRS Schedule K 15 p. 16 8
9 p. 17 Schedule K - Part I - Identification of Bond Issues Name of Issuer Issuer EIN CUSIP # Date Issued Issue Price Description of Purpose Defeased On behalf of Issuer Pooled Financing 18 9
10 Schedule K - Part II - Use of Proceeds Some of the information for Part II should be on IRS Form 8038 Other information for Part II is based on actual post-issuance facts 2011 version of Schedule K contains more elaborate questions than previous versions 19 Schedule K - Part II - Use of Proceeds New questions on 2011 Schedule K Line 1: Amount of Bonds retired Line 2: Amount of Bonds legally defeased Line 5: Capitalized interest from proceeds Line 6: Proceeds in refunding escrows Line 8: Credit enhancement from proceeds Line 11: Other spent proceeds Line 12: Other unspent proceeds 20 10
11 Schedule K - Part II - Use of Proceeds Other Important Questions Line 7: Issuance Costs from proceeds (Why?) Line 9: Working Capital Expenditures from proceeds (Why?) Line 13: Year of Substantial completion (Why?) 21 Schedule K - Part II - Use of Proceeds Line 16 - Has the Final Allocation of Proceeds Been Made? A final allocation must be done no later than 18 months after the later of: (i) the date of the expenditure, or (ii) the date the property is placed in service (in any event, no later than 60 days after the fifth anniversary of the issue date) Important in transactions in which non-bond proceeds need to be used to finance private use space which does not fit within the permissible bad money portion of the bond issue (generally 3%) 22 11
12 Schedule K - Part II - Use of Proceeds Line 17 - Does the Organization Maintain Adequate Books & Records to Support the Final Allocation of Bond Proceeds? What Are the Records to be Maintained? Basic records relating to the bond transaction, including the trust indenture, bond resolution, loan agreements, and bond counsel opinion Documentation evidencing expenditure of bond proceeds Documentation evidencing use of bond financed property by public and private sources such as copies of management contracts, research agreements, and lease agreements Documentation pertaining to the investment of bond proceeds 23 Schedule K - Part II - Use of Proceeds How Long Should Records be Kept? As long as the bonds are outstanding, plus 3 years If the bonds are refunded, need to retain records for the life of the original bonds and refunding bonds, plus 3 years 24 12
13 Schedule K - Part III - Private Business Use Question 2 - Are there any lease arrangements that may result in private business use of bond-financed property? Question 3a - Are there any management or service contracts that may result in private business use of bond-financed property? Question 3b If Yes to line 3a, does the organization routinely engaged bond counsel or other outside counsel to review any management or service contracts relating to the financed property? Answer should be Yes 25 Schedule K - Part III - Private Business Use Question 3c - Are there any research agreements that may result in private business use of bond-financed property? Question 3d If Yes to line 3c, does the organization routinely engaged bond counsel or other outside counsel to review any research agreements relating to the financed property? Answer should be Yes 26 13
14 Schedule K - Part III - Private Business Use Question 4 - Enter the percentage of financed property used in private business use by entities other than a 501(c)(3) organization or a state or local government Calculation Required: % Instructions: Do not include any use relating to management or research contracts that the organization has determined to meet the IRS safe harbor rules 27 Schedule K - Part III - Private Business Use Question 5 - Enter the percentage of financed property used in a private business use as a result of unrelated trade or business activity carried on by your organization, another 501(c)(3) organization or a state or local government Calculation Required: % 28 14
15 Schedule K - Part III - Private Business Use Question 7 - Has the organization adopted management practices and procedures to ensure the post-issuance compliance of its tax-exempt bond liabilities? Answer should be Yes 29 Schedule K - Part IV - Arbitrage Question 1 - Has a rebate analysis been performed and an IRS Form 8038-T filed? Question 3a - Has the organization or the governmental issuer entered into a qualified hedge with respect to the bond issue? Question 4a - Were the proceeds invested in a Guaranteed Investment Contract (GIC)? 30 15
16 Difference in Annual Reporting Requirements v. General Tax Principles Schedule K private use activities measured over a 12 month reporting period (annual snap shot) Federal Tax Principles generally, private use activities measured over the entire life of the bonds, plus any refunding bonds Observation An organization could have a situation where the reported private use for Schedule K purposes is significant while at the same time the bond issue remains tax-exempt under general federal tax law principles 31 III. Examples of Private Business Use and How to Measure It 32 16
17 How to Measure Private Use Non-profit borrowers often lack the technical expertise to properly navigate through the annual private use calculations How to Measure Private Use 34 17
18 Examples of Potential Private Use of Bond-Financed Property Cafeteria Contracts Gift Shops Non-Employee Contracts Outside Parties Physician Groups Leases of Property Research Agreements Food Court Starbucks Certain Parking Agreements Use by other 501(c)(3) Organizations Central Utility Plant 35 How to Measure Private Use Fundamentals - getting started to complete Part III of Schedule K Identify property financed by each issue of outstanding bonds issued after 12/31/02. Was the original bond issue refunded? If so, by what bond issue? Who uses that space? How much space are they using and for how long? Is there any private use or unrelated trade or business use? Did the 501(c)(3) allocate equity to any portion of the facility? What records support the allocation of bond proceeds and/or equity to that facility? 36 18
19 How to Measure Private Use 4 Primary Methods Square footage Time of use Time/space analysis Revenues Under the applicable tax regulations, the measurement of private use must be reasonable. Determining what method is most appropriate may require professional judgment. 37 How to Measure Private Use Private Use Example $100 million bond issue which financed 3 facilities Emergency Room Renovation - $25 million Research Building - $50 million 10 - Story Hospital building with Cafeteria - $25 million 38 19
20 How to Measure Private Use Emergency Room Renovation Example Users: General Public Non-employee physician management contract (PC) Contract does not meet Rev. Proc How to Measure Private Use Emergency Room Renovation Example (cont.) Observations regarding physician use Non-employee physician use spans entire renovation Some employee doctors and nurses also use the ER space when examining and admitting patients 40 20
21 How to Measure Private Use Emergency Room Renovation Example (cont.) Main hospital square footage - 1 million square feet Emergency room square footage - 55,000 square feet Hospital annual revenues - $300 million Emergency room annual revenues - $6 million 41 How to Measure Private Use Emergency Room Renovation Example (cont.) Q: How do you measure private use? A 365 days = 100.0% 365 days B 55,000 sq. ft. = 5.5% 1,000,000 sq. ft. C $6,000,000 = 2.0% $300,000,
22 How to Measure Private Use Research Building Users: Hospital Employees Hospital has 1,000 research contracts within bond financed space Under intake review process, 75 contracts do not meet Revenue Procedure How to Measure Private Use Research Building Example (cont) All research takes place concurrently Substantially all the lab equipment will be continuously available for both good and bad research The identity of researchers at the location of research will undergo change over time 44 22
23 How to Measure Private Use Research Building Example (cont.) How do you measure private use: Time? Square Footage? Revenues? 45 How to Measure Private Use Research Building Example (cont.) Measure Private use based on Research Revenues Private Use Research Revenues $150,000 Total Research Revenues $ 2,000,000 Private business use $150,000 = 7.5% $2,000,000 * Annual calculation required based on present value 46 23
24 How to Measure Private Use Hospital Building with Cafeteria Example Hospital is used 365 days a year Users: Visitors/Faculty Sodexho operates cafeteria under management contract Building is 10 stories 9 Floors of Beds 1 Floor Cafeteria 47 p. How to Measure Private Use Hospital Building with Cafeteria Example (cont.) Sodexho Management Contract All Revenues to Sodexho Sodexho pays $100,000 per year to Hospital (Lease?) 1 Floor Cafeteria Questions: Was equity allocated to the Sodexho space? Do Hospital records support an equity allocation? 48 24
25 p. How to Measure Private Use Hospital Building with Cafeteria Example (cont.) Assume each floor costs $2.5 million Use by Sodexho 100% x $2.5 million = $2,500,000 Total = $2,500,000 Cafeteria - $2,500,000 = 10.00% $25,000, p. How to Measure Private Use $100 million bond issue which financed 3 facilities Summary Project Name Private Use (%) Bond Proceeds Spent on Project Private Use Cost Figure Research Building 7.50% $50,000,000 $3,750,000 Hospital Building with Cafeteria 10.00% $25,000,000 $2,500,000 Emergency Room Renovation % $25,000,000 $25,000,000 Total $31,250,000 Net Sale Proceeds $100,000,000 Private Use (%) 31.25% 50 25
26 p. 51 p. Contact Information Ed Oswald Orrick John V. Woodhull Crowe Horwath LLP
AMERICAN HEALTH LAWYERS ASSOCIATION Tax Issues for Healthcare Organizations October 15-16, 2012
AMERICAN HEALTH LAWYERS ASSOCIATION Tax Issues for Healthcare Organizations October 15-16, 2012 Elements of a Post-Issuance Tax Compliance Program for Tax-Exempt Bonds Edwin G. Oswald, Esq. Orrick, Herrington
More informationUNDERSTANDING PRIVATE BUSINESS USE OF TAX EXEMPT BONDS. Presented by: Caleb Lansky, BLX Group
UNDERSTANDING PRIVATE BUSINESS USE OF TAX EXEMPT BONDS Presented by: Caleb Lansky, BLX Group PRIVATEBUSINESS USE OVERVIEW AND EXCEPTIONS The hardest thing to understand in the world is the income tax.
More informationForm 990, Schedule K and Tax-Exempt Bonds
Form 990, Schedule K and Tax-Exempt Bonds May 25, 2010 1:00 pm EST DRAFT If you experience any technical difficulties, please contact 888.228.4388 or GTU_support@learnlive.com Addressing your questions
More informationPrivate Activity Use and Tax Requirements for Construction Projects Workshop
***Important Note*** This information is for Internal CSU purpose only. Do not distribute as the information may be incomplete and subject to change. The CSU and its bond counsel do not make any assurances
More informationA Roadmap to Post-Issuance Tax Compliance. Presented by: Alan Bond, BLX Group Larry Sobel, Orrick John Cebula, Chapman University
A Roadmap to Post-Issuance Tax Compliance Presented by: Alan Bond, BLX Group Larry Sobel, Orrick John Cebula, Chapman University 1 Discussion Outline I. Post-Issuance Tax Compliance Overview II. Private
More informationGuide to Identifying and Measuring Private Business Use in Tax-Exempt Bond-Financed Facilities
Guide to Identifying and Measuring Private Business Use in Tax-Exempt Bond-Financed Facilities I. Introduction The University of Washington (the University ) frequently finances facilities in whole or
More informationTAX COMPLIANCE POLICIES TAX-EXEMPT GOVERNMENTAL BONDS
TAX COMPLIANCE POLICIES TAX-EXEMPT GOVERNMENTAL BONDS 1. Purpose Issuers of tax-exempt governmental bonds must comply with federal tax rules pertaining to expenditure of proceeds for qualified costs, rate
More informationAHLA. B. What s Up with Rev. Proc Brenda S. Horn Ice Miller LLP Indianapolis, IN. Elizabeth M. Mills Proskauer Rose LLP Chicago, IL
AHLA B. What s Up with Rev. Proc. 97-13 Brenda S. Horn Ice Miller LLP Indianapolis, IN Elizabeth M. Mills Proskauer Rose LLP Chicago, IL Tax Issues for Health Care Organizations October 19-21, 2014 What
More informationTAX EXEMPT FINANCING BASICS FOR SECTION 501(C)(3) ORGANIZATIONS
American Health Lawyers Association Tax Issues for Healthcare Organizations October 21 & 22, 2013 TAX EXEMPT FINANCING BASICS FOR SECTION 501(C)(3) ORGANIZATIONS TODD GIBSON SQUIRE SANDERS (US) LLP JULIE
More informationMunicipal Finance Post-Issuance Legal Compliance
Municipal Finance Post-Issuance Legal Compliance Erin McCrady, Partner Dorsey & Whitney LLP Montana League of Cities and Towns Annual Conference September 28, 2017 Post-Issuance Legal Compliance The municipal
More informationLAw OFFrCE OF PERRY ISRAEL
LAw OFFrCE OF PERRY ISRAEL 3436 American River Drive, Suite 9 Sacramento, CA 95864 916-485-6645 perry@ 1031aw. com POST-IsSUANCE COMPLIANCE FOR TAX-ExEMPT BONDS Living with a Tax-Exempt Bond Issue Your
More informationPOST ISSUANCE COMPLIANCE UPDATE
POST ISSUANCE COMPLIANCE UPDATE Alan Bond Managing Director abond@blxgroup.com (212) 506-5275 Erik Dingwall Managing Director edingwall@blxgroup.com (813) 872-6840 Post-Issuance Tax Compliance Training
More informationDEVELOPING AND IMPLEMENTING PROCEDURES FOR POST-ISSUANCE TAX COMPLIANCE FOR ISSUERS OF GOVERNMENTAL BONDS GFOA DEBT COMMITTEE
DEVELOPING AND IMPLEMENTING PROCEDURES FOR POST-ISSUANCE TAX COMPLIANCE FOR ISSUERS OF GOVERNMENTAL BONDS GFOA DEBT COMMITTEE AUGUST 2016 DEVELOPING AND IMPLEMENTING PROCEDURES FOR POST-ISSUANCE TAX COMPLIANCE
More informationAHLA. C. Tax-Exempt Financing Basics for Section 501(c)(3) Organizations. L. Todd Gibson Squire Sanders (US) LLP Cleveland, OH
AHLA C. Tax-Exempt Financing Basics for Section 501(c)(3) Organizations L. Todd Gibson Squire Sanders (US) LLP Cleveland, OH Julie K. Seymour Ungaretti & Harris LLP Chicago, IL Tax Issues for Health Care
More informationTax-Exempt Debt Post-Issuance Compliance Situation and Recommendation
Tax-Exempt Debt Post-Issuance Compliance Situation and Recommendation Information provided by: Janice Essenberg, Chief Financial Officer Situation: On October 13, 2016 NWRESD completed a debt refinancing/roof
More information1808 TAX-EXEMPT BOND POLICIES
Financial Manual Effective: December 1986 Last Revision: June 2012 Last Reviewed: April 2017 Responsible Office: Treasurer s Office Approval: V.P. for Finance and Treasurer 1808 TAX-EXEMPT BOND POLICIES
More informationTAX COMPLIANCE AGREEMENT. Dated as of January 1, Among CITY OF WESTWOOD, KANSAS, MIDWEST TRANSPLANT NETWORK, INC., And
TAX COMPLIANCE AGREEMENT Dated as of January 1, 2014 Among CITY OF WESTWOOD, KANSAS, MIDWEST TRANSPLANT NETWORK, INC., And COMMERCE BANK, as Bond Trustee Not To Exceed $8,00,0000 Industrial Revenue Bonds
More informationPRIVATE BUSINESS USE WORKSHOP. April 27, 2017
PRIVATE BUSINESS USE WORKSHOP April 27, 2017 Development Team > Planning for this workshop involved a large team and a wide variety of departments across campus Capital and Space Management College of
More informationTax-exempt bonds and the private business use dilemma
Tax-exempt bonds and the private business use dilemma Presenters Chad Franks Tax Principal KPMG LLP Edward N. Lee Audit Partner KPMG LLP Agenda 1 Post-issuance compliance Overview of basic rules and common
More informationChapter 8: BUSINESS 8041 Section 6: BONDING. Tax Compliance and Record Retention for Tax-Exempt Governmental Bonds
Chapter 8: BUSINESS 8041 Section 6: BONDING Tax Compliance and Record Retention for Tax-Exempt Governmental Bonds Definitions Advisors means the Issuer s Bond Counsel, Financial Advisor, paying agent,
More informationSECTION 2. BACKGROUND
Rev. Proc. 2007-47 Table of Contents SECTION 1. PURPOSE SECTION 2. BACKGROUND SECTION 3. DEFINITIONS SECTION 4. CHANGES SECTION 5. SCOPE SECTION 6. OPERATING GUIDELINES FOR RESEARCH AGREEMENTS SECTION
More informationPOST-ISSUANCE TAX COMPLIANCE
Brandeis University Post-Issuance Tax Compliance Procedures For Tax-Exempt Obligations I. INTRODUCTION These post-issuance compliance procedures of Brandeis University (the Institution ) are designed to
More informationUniversity of North Carolina Wilmington. Tax-Exempt Debt, State Bonds, and Build America Bond Post-Issuance Tax Compliance Memorandum
University of North Carolina Wilmington Tax-Exempt Debt, State Bonds, and Build America Bond Post-Issuance Tax Compliance Memorandum May 8, 2017 Table of Contents Part I. Part II. Part III. Part IV. Part
More informationnonprofit alert THE EVOLVING SCHEDULE K TO IRS FORM 990: SUPPLEMENTAL INFORMATION ON TAX-EXEMPT BONDS HINTS FOR THE WISE AND TRAPS FOR THE UNWARY
nonprofit alert AUTHORS: Walter R. Calvert wrcalvert@venable.com 410.244.7726 Tammara F. Langlieb tflanglieb@venable.com 410.244.7821 IN COLLABORATION WITH: Caryn G. Pass cgpass@venable.com 202.344.8039
More informationPost-Issuance Compliance Policy For Tax-Exempt and Tax-Credit Bonds
Policy V. 4.15.1 Responsible Official: Vice President for Finance and Treasurer Effective Date: January 6, 2015 Post-Issuance Compliance Policy Policy Statement It is the University s policy to comply
More information501(c)(3) Bonds 101. Title Goes Here. Subtitle Goes Here. (Webinar Presentation) Marc A. Feller Samuel T. Cooper, III, and
Title Goes Here 501(c)(3) Bonds 101 Subtitle Goes Here (Webinar Presentation) Marc A. Feller Samuel T. Cooper, III, and Presenter s Mark H. Vacha Name Here Date Tuesday Goes June Here8, 2010 Disclaimer
More informationDEBT FINANCING POLICIES
DEBT FINANCING POLICIES 1801 Debt Financing Selection 1802 Determination of Debt Capacity 1803 Debt Management Operation 1804 Debt Management Capital Projects 1805 Bank Lines of Credit 1806 Bank Letters
More informationSTOCKTON UNIVERSITY PROCEDURE. Purpose
STOCKTON UNIVERSITY PROCEDURE Tax Exempt Bond Compliance Procedure Administrator: Assistant Vice President for Finance Authority: IRS Revenue Procedures 97-13 and 2007-47, Treasury Regulation 1.141-12,
More informationRollins College Bond Compliance Policies
Rollins College Bond Compliance Policies Arbitrage Policy and Procedural Guidelines The purpose of the Arbitrage Policy and Procedural Guidelines is to assure that proceeds of tax exempt bonds comply with
More informationPOST-ISSUANCE COMPLIANCE
BLX Group LLC 2711 N. Haskell Avenue Lockbox 35, Suite 2600 SW Dallas, TX 75204 ph: 214-989-2700 fax: 214-989-2712 www.blxgroup.com POST-ISSUANCE COMPLIANCE Presented by: Sandee Stallings, BLX Group September
More informationTopic: POLICY FOR POST ISSUANCE TAX-EXEMPT BOND COMPLIANCE Policy # FAR-2 Version: 1 Effective Date: 05/01/2012. Purpose:
Topic: POLICY FOR POST ISSUANCE TAX-EXEMPT BOND COMPLIANCE Policy # FAR-2 Version: 1 Effective Date: 05/01/2012 Purpose: The purpose of these post-issuance compliance policies for tax-exempt bonds and
More informationBoard of Directors Governance & Policies
Resolution No.: 12-20 Bond Compliance Procedure Responsible Department: Administration / Finance & Accounting Effective Date: March 19, 2012 Supersedes: N/A Personnel Covered: All Employees POLICY STATEMENT
More informationPrivate Use of Public Community College Facilities (312) (309)
Private Use of Public Community College Facilities Erin Bartholomy Kevin Heid (312) 845-3893 (309) 829-7927 bartholo@chapman.com kevin@firstmidstate.com 2986977 Private Activity and Tax Exemption General
More informationPost-Issuance Tax-Exempt Bond Compliance Policy
Post-Issuance Tax-Exempt Bond Compliance Policy Responsible Office Finance Division Effective Date March 7, 2012 Responsible Official Sr. VP for Finance & COO Last Revision May 10, 2016 Policy Sections
More informationPOST ISSUANCE (OF DEBT) COMPLIANCE
POST ISSUANCE (OF DEBT) COMPLIANCE BARABOO SCHOOL BOARD POLICY 632 Statement of Purpose This Post-Issuance Compliance Policy (the "Policy") sets forth specific policies of the School District of Baraboo,
More informationTax-Exempt Governmental Bonds
Internal Revenue Service Tax Exempt and Government Entities Tax-Exempt Governmental Bonds Compliance Guide from the office of Tax Exempt Bonds Know the federal tax rules and filing requirements applicable
More informationOKANOGAN SCHOOL DISTRICT NO. 105, OKANOGAN COUNTY, WASHINGTON POST ISSUANCE COMPLIANCE POLICY
Policy 6915 Governmental Bonds OKANOGAN SCHOOL DISTRICT NO. 105, OKANOGAN COUNTY, WASHINGTON POST ISSUANCE COMPLIANCE POLICY This policy is intended to guide Okanogan School District No. 105, Okanogan
More informationSAMPLE PRIVATE USE ANALYSIS. UW Sample Building
1 SAMPLE PRIVATE USE ANALYSIS UW Sample Building 2 UW Sample Building Project The UW Building is a 4-story research facility located in UW Medicine s South Lake Union campus. It was developed by a 501(c)(3)
More informationPost-Issuance Compliance Policy for Tax-Exempt and Tax-Advantaged Obligations and Continuing Disclosure. Adopted:, 20
Post-Issuance Compliance Policy for Tax-Exempt and Tax-Advantaged Obligations and Continuing Disclosure Adopted:, 20 Statement of Purpose This Post-Issuance Compliance Policy (the "Policy") sets forth
More informationPost Issuance Policies and Procedures for Tax-Exempt Bond Obligations
Post Issuance Policies and Procedures for Tax-Exempt Bond Obligations Introduction This Post-Issuance Compliance Policies and Procedures (this "Policy and Procedures") sets forth specific policies and
More informationPOST-ISSUANCE COMPLIANCE TRAINING: TAX RULES AND EMMA. WPTA Annual Conference, April 13, 2017
POST-ISSUANCE COMPLIANCE TRAINING: TAX RULES AND EMMA WPTA Annual Conference, April 13, 2017 Tax Sarah Kuipers, Foster Pepper Tax Discussion Topics Purpose of post-issuance compliance policies Form of
More informationMCG Health, Inc. d/b/a Georgia Regents Medical Center (a component unit of MCG Health System, Inc.)
Financial Statements and Report of Independent Certified Public Accountants MCG Health, Inc. d/b/a Georgia Regents Medical Center June 30, 2015 and 2014 MCG Health, Inc. Table of contents Management s
More informationCITY OF MONT BELVIEU CITY COUNCIL POLICY
Page 1 of 20 COMPLIANCE OFFICER: Name/Title Signature Date PURPOSE: The purpose of this post-issuance compliance policy and procedure manual is to adopt policies and procedures to guide the City of Mont
More informationfocus on ongoing compliance issues relating to outstanding indebtedness.
BEYOND THE CLOSING A Guide to Post-Issuance Compliance Presented by: Womble Carlyle Sandridge & Rice, PLLC Paul H. Billow G. Thomas Lee Activities relating to a bond issue do not end at closing. This presentation
More informationTax-Exempt Governmental Bonds
Tax-Exempt Governmental Bonds Compliance Guide from the office of Tax Exempt Bonds Know the federal tax rules and filing requirements applicable to governmental bonds Contents Background...2 Tax-Exempt
More informationArkansas State University. Tax Exempt Bond Post-Issuance Compliance Manual
Arkansas State University Tax Exempt Bond Post-Issuance Compliance Manual Effective Date: January 1, 2012 Arkansas State University System Post-Issuance Compliance Policy Manual Section 1. Introduction
More informationAspen Valley Hospital District
Independent Auditor s Report and Financial Statements Contents Independent Auditor s Report on Financial Statements and Supplementary Information... 1 Management s Discussion and Analysis... 3 Financial
More informationTax-Exempt Bonds for 501(c)(3) Charitable Organizations
Internal Revenue Service Tax Exempt and Government Entities Tax-Exempt Bonds for 501(c)(3) Charitable Organizations Compliance Guide from the office of Tax Exempt Bonds Know the federal tax rules and filing
More informationSection III.C.1. Debt Management Tax-Exempt Bond Post-Issuance Compliance Procedures
Section III.C.1. Debt Management Tax-Exempt Bond Post-Issuance Compliance Procedures These procedures supplement and clarify Section III.C.1 of the Lone Star College District Policy Manual last revised
More informationAppendix 26B. Public Health Care Organizations
Appendix 26B Public Health Care Organizations 1 2 APPENDIX 26B PUBLIC HEALTH CARE ORGANIZATIONS Recall from the chapter that of the four types of not-for-profit organizations (NPOs), only these two types
More informationCost Reporting Principles April 4, 2007
Reimbursement Primer for Compliance, Ethics and Legal Officers: Everything You Have Always Wanted to Know About Reimbursement but Were Afraid to Ask. Cost Reporting Principles April 4, 2007 Douglas J.
More informationMaintenance of Personnel. Costed Requisitions. Rev
01-10 FORM CMS-2552-96 3617 3617. WORKSHEET B, PART I - COST ALLOCATION - GENERAL SERVICE COSTS AND WORKSHEET B-1 - COST ALLOCATION - STATISTICAL BASIS Base cost data on an approved method of cost finding
More informationWIND PRODUCTION TAX CREDITS
WIND PTC WIND PRODUCTION TAX CREDITS The production tax credit ( PTC ) generally is available to a taxpayer investing in a wind facility when the taxpayer: produces electricity from qualified energy resources
More informationBLX Group LLC. 777 S. Figueroa St., Suite Los Angeles, California CRD Number
BLX Group LLC 777 S. Figueroa St., Suite 3200 Los Angeles, California 90017 213-612-2200 www.blxgroup.com CRD Number 111923 March 27, 2018 Form ADV, Part 2A This Brochure provides information about the
More informationSUNY/PPAA WINTER CONFERENCE Office for Capital Facilities February 2019
SUNY/PPAA WINTER CONFERENCE Office for Capital Facilities February 2019 1 Updates NY HE LSRE Project NFPA Red Cross Cold Weather AiM Updates Grant Specialist Campus Lets Private Use 2 NEW YORK HIGHER ED
More informationAn Update on Implementation of New Management Contract Safe Harbors for Property Financed with Tax-Exempt Bonds
An Update on Implementation of New Management Contract Safe Harbors for Property Financed with Tax-Exempt Bonds (Rev. Proc. 2017-13) Michael G. Bailey Foley & Lardner LLP An Update on Implementation of
More informationFEDERAL TAX CERTIFICATE. Dated as of February 15, 2012 UNIFIED SCHOOL DISTRICT NO. 261, SEDGWICK COUNTY, KANSAS (HAYSVILLE)
Gilmore & Bell, P.C. 01/17/2012 FEDERAL TAX CERTIFICATE Dated as of February 15, 2012 OF UNIFIED SCHOOL DISTRICT NO. 261, SEDGWICK COUNTY, KANSAS (HAYSVILLE) $2,225,000* GENERAL OBLIGATION REFUNDING BONDS
More informationWHEREAS, the Borough has requested the assistance from the Middlesex County Improvement Authority (the "Authority") in financing the Project; and
RES: 2018-124 RESOLUTION OF THE BOROUGH OF SPOTSWOOD DECLARING ITS OFFICIAL INTENT TO REIMBURSE EXPENDITURES FOR PROJECT COSTS FROM THE PROCEEDS OF DEBT OBLIGATIONS OF THE BOROUGH, INCLUDING IN CONNECTION
More informationCost Reporting 101: Your Medicare Cost Report from A - M
Cost Reporting 101: Your Medicare Cost Report from A - M Paul Traczek, CPA, Partner Holly Pokrandt, CPA, Partner September 27, 2018 Cost Reporting 101: A Crash Course in the Basics What will be covered
More informationTennessee GFOA 2017 Spring Institute
Tennessee GFOA 2017 Spring Institute Post Issuance Compliance: What Do I Need To Know? Mike Steinbrook, Director steinbrookm@pfm.com PFM Asset Management LLC One Keystone Plaza 717.232.2723 Suite 300 pfm.com
More informationE. UNIVERSITY FINANCIAL SERVICES E Tax-Advantaged Bond Post Issuance Compliance Policy. Table of Contents
Table of Contents I. Purpose II. Definitions III. Responsibilities A. University Financial Services Administration B. Accounting and Financial Reporting Services C. Capital Projects Management Division
More informationNOT-FOR-PROFIT NEWSLETTER
WINTER 2017 Certified Public Accountants Business Consultants NOT-FOR-PROFIT NEWSLETTER istockphoto thinkstock IN THIS ISSUE A List of Projects from the IRS s 2016 2017 Priority IRS Updates Safe Harbor
More informationPost Issuance Compliance
Post Issuance Compliance Joan M. DiMarco, Managing Director PFM Asset Management LLC Arbitrage Rebate and Post Issuance Compliance Group Two Logan Square Suite 1600 Philadelphia, PA 19103 Phone: 215-667-6100
More informationPort Administration & Legal Issues Seminar
Title Slide Place image here in this top corner Size: 2.58 x 2.58 Position: horizontal 0, vertical 0 Port Administration & Legal Issues Seminar Federal Tax Law Considerations Travis Gibbs Nixon Peabody
More informationSafety Net Grant Program
Safety Net Grant Program Description: The National Pediatric Cancer Foundation s Safety Net Grant Program assists cancer patients (children under the age of 18) with advanced cancer treatment related costs.
More informationPOST ISSUANCE COMPLIANCE FOR GOVERNMENTAL BONDS
POST ISSUANCE COMPLIANCE FOR GOVERNMENTAL BONDS Policy No. 6050 Scope. This Post Issuance Compliance Policy addresses the Issuer s compliance with federal tax, federal securities and state law requirements
More informationThe Board of Regents for the Oklahoma Agricultural and Mechanical Colleges. Debt Issuance and Management Guidelines
The Board of Regents for the Oklahoma Agricultural and Mechanical Colleges Debt Issuance and Management Guidelines November 2011 TABLE OF CONTENTS Project Planning / Identification of Potential Funding
More information25th Annual Health Sciences Tax Conference
25th Annual Health Sciences Tax Conference Reading the tea leaves for tax-exempt health plans in a post-vision Service Plan and ACA world December 7, 2015 Disclaimer EY refers to the global organization,
More informationPublic Finance Authority Post-Issuance Tax Compliance Procedures For Tax-Exempt Bonds (Multifamily Housing)
Public Finance Authority Post-Issuance Tax Compliance Procedures For Tax-Exempt Bonds (Multifamily Housing) August 3, 2011 The purpose of these Post-Issuance Tax Compliance Procedures is to establish policies
More informationFrequently Asked Questions and Answers on IRS Form 1095-C
Frequently Asked Questions and Answers on IRS Form 1095-C Q1. What is Form 1095-C? A1: The IRS will use the information provided on Form 1095-C to administer the Employer Shared Responsibility provisions
More informationHigher Ed, Exempt Org & Governmental Financings
Higher Ed, Exempt Org & Governmental Financings Tax Presentation November 2016 Orrick, Herrington & Sutcliffe, LLC Larry Sobel Kathryn Garner Chas Cardall Table of Contents Qualified Equity - Allocation
More informationNotice of Proposed Rulemaking and Notice of Public Hearing. Remedial Actions for Tax-Exempt Bonds REG Background
Notice of Proposed Rulemaking and Notice of Public Hearing Remedial Actions for Tax-Exempt Bonds REG 132483 03 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Notice of proposed rulemaking and
More informationTax Exempt Debt Compliance Policy
Tax Exempt Debt Compliance Policy Policy Type: Board of Visitors Responsible Office: Treasury Services Initial Policy Approved: 02/09/2012 Current Revision Approved: 10/21/2014 Policy Statement and Purpose
More informationAffordable Care Act Update
Affordable Care Act Update CLAconnect.com May 19, 2015 Presented by: Anita Baker Session Objectives Identify key definitions impacting employer implementation of the Affordable Care Act Understand the
More informationFinancial Statements and Report of Independent Certified Public Accountants. AU Medical Center, Inc. (a component unit of AU Health System, Inc.
Financial Statements and Report of Independent Certified Public Accountants AU Medical Center, Inc. June 30, 2017 and 2016 AU Medical Center, Inc. Table of contents Management s discussion and analysis
More informationREMEDIAL ACTION. Courtney A. Strutt Todd Davis Brown Law Firm 2013 DAVIS BROWN KOEHN SHORS & ROBERTS P.C.
REMEDIAL ACTION Courtney A. Strutt Todd Davis Brown Law Firm REASONABLE EXPECTATIONS TEST Issuer must reasonably expect on the issue date to satisfy all applicable federal tax requirements for so long
More informationTAX COMPLIANCE CERTIFICATE
KUTAK DRAFT 12/4/15 TAX COMPLIANCE CERTIFICATE $[ ] State of Colorado, Department of Higher Education by State Board for Community Colleges and Occupational Education Systemwide Revenue Bonds (Red Rocks
More informationRev. Proc CLICK HERE to return to the home page. Table of Contents
CLICK HERE to return to the home page Rev. Proc. 2015-53 Table of Contents SECTION 1. PURPOSE SECTION 2. CHANGES SECTION 3. 2016 ADJUSTED ITEMS SECTION 4. EFFECTIVE DATE SECTION 5. DRAFTING INFORMATION
More informationCost Allocation. Overview. Allocation Definition. Multi-award Cost Allocation
Cost Allocation Overview This guidance is designed to provide assistance to campus users when direct charging costs to multiple benefiting sponsored awards and to comply with the direct charging principles
More informationMARY S WOODS AT MARYLHURST, INC. Financial Statements. June 30, 2013 and (With Independent Auditors Report Thereon)
Financial Statements (With Independent Auditors Report Thereon) KPMG LLP Suite 3800 1300 South West Fifth Avenue Portland, OR 97201 Independent Auditors Report The Board of Directors Mary s Woods at Marylhurst,
More informationLAKELAND REGIONAL HEALTH SYSTEMS, INC. AND SUBSIDIARIES. Consolidated Financial Statements. September 30, 2017
Consolidated Financial Statements (With Independent Auditors Report Thereon) Table of Contents Page Independent Auditors Report 1 Consolidated Financial Statements: Consolidated Balance Sheet 3 Consolidated
More informationPERSPECTIVE HEALTHCARE WIPFLI. Critical Access Hospital Medicare Cost Report - Annual Checkup. December 2007
WIPFLI HEALTHCARE December 2007 expert advice innovative solutions performance improvement PERSPECTIVE Critical Access Hospital Medicare Cost Report - Annual Checkup While filing a Medicare cost report
More informationDOWNTOWN DORAL CHARTER ELEMENTARY SCHOOL, INC. FINANCIAL STATEMENTS WITH INDEPENDENT AUDITORS REPORTS THEREON JUNE 30, 2016
FINANCIAL STATEMENTS WITH INDEPENDENT AUDITORS REPORTS THEREON JUNE 30, 2016 TABLE OF CONTENTS Report of Independent Auditors on Basic Financial Statements and Supplementary Information 1-2 Management's
More informationSummary of 6055 and 6056 Reporting Obligations
Summary of 6055 and 6056 Reporting Obligations On March 10, 2014, the IRS released final regulations detailing the reporting requirements for information returns and individual statements under Code 6055
More informationJUPITER MEDICAL CENTER, INC. AND AFFILIATED COMPANIES. Jupiter, Florida. CONSOLIDATED FINANCIAL STATEMENTS September 30, 2014 and 2013
JUPITER MEDICAL CENTER, INC. AND AFFILIATED COMPANIES Jupiter, Florida CONSOLIDATED FINANCIAL STATEMENTS Jupiter, Florida CONSOLIDATED FINANCIAL STATEMENTS CONTENTS INDEPENDENT AUDITOR S REPORT... 1 FINANCIAL
More informationCooper Square Housing Development Fund Company, Inc. HUD Project No. 012-EH-243
Cooper Square Housing Development Fund Company, Inc. Financial Statements and Supplementary Information June 30, 2017 and 2016 Table of Contents June 30, 2017 and 2016 Independent Auditors Report 1 Financial
More informationFederal Regulatory Update
Federal Regulatory Update Robert L. Gauss, Partner Ice Miller LLP One American Square, Suite 2900 Indianapolis, IN 46282-0200 (317) 236-2133 gauss@ Current Topics Status of IRS Determination Letter program.
More informationAHLA. Tax Primer. Tricia M. Johnson, CPA Executive Director Ernst & Young LLP Cincinnati, OH
AHLA Tax Primer Tricia M. Johnson, CPA Executive Director Ernst & Young LLP Cincinnati, OH Cynthia Leon Vice President, Transactions and Tax Catholic Health Initiatives Denver, CO Tax Issues for Health
More informationJUPITER MEDICAL CENTER, INC. AND AFFILIATED COMPANIES. Jupiter, Florida. CONSOLIDATED FINANCIAL STATEMENTS September 30, 2015 and 2014
JUPITER MEDICAL CENTER, INC. AND AFFILIATED COMPANIES Jupiter, Florida CONSOLIDATED FINANCIAL STATEMENTS Jupiter, Florida CONSOLIDATED FINANCIAL STATEMENTS CONTENTS INDEPENDENT AUDITOR S REPORT... 1 FINANCIAL
More informationRepair Regulations and your 2013 Tax Returns What You Need to Know Presenter: Roger Upton
Repair Regulations and your 2013 Tax Returns What You Need to Know Presenter: Roger Upton Who We Are We re made up of tax, construction, and engineering professionals. Years of experience: Cost Segregation
More informationDONALD A. DEVLIN & ASSOCIATES, PC
DONALD A. DEVLIN & ASSOCIATES, PC 807 Bay Avenue Somers Point, NJ 08244 (P) 609-926-6400 (F) 609-926-6426 IDENTITY AUTHENTICATION Driver s License or State Issued Identification Government agencies are
More informationAccounting for Health Care Organizations. Chapter 18
Accounting for Health Care Organizations Chapter 18 Learning Objectives Account for unique hospital revenue sources Prepare journal entries for hospital transactions Prepare government hospital financial
More informationRevenue Cycle Performance
Crowe Healthcare Summit Revenue Cycle Performance Unclaimed Property Done Right Audit Tax Advisory Risk Performance 2015 Crowe Horwath LLP What is Unclaimed Property? Unclaimed Property & Escheat 54 U.S.
More informationBuena Vida Corp. d/b/a Buena Vida Continuing Care and Rehabilitation Center
d/b/a Buena Vida Continuing Care and Rehabilitation Center Financial Statements Independent Auditor's Report Board of Directors We have audited the accompanying financial statement of financial position
More informationReport of Independent Auditors and Financial Statements for. Central Washington Health Services Association dba Central Washington Hospital
Report of Independent Auditors and Financial Statements for Central Washington Health Services Association dba Central Washington Hospital December 31, 2016 and 2015 CONTENTS REPORT OF INDEPENDENT AUDITORS
More informationCLAREMONT MCKENNA COLLEGE Claremont, California EIN A1 Independent Auditor's Report in Accordance with Uniform Guidance and Financial
Claremont, California EIN 1-951664101-A1 Independent Auditor's Report in Accordance with Uniform Guidance and Financial Statements INDEPENDENT AUDITOR'S REPORT IN ACCORDANCE WITH UNIFORM GUIDANCE AND FINANCIAL
More informationCost Report Compliance Issues for Critical Access Hospitals
Cost Report Compliance Issues for Critical Access Hospitals OIG s Compliance Guidance Model Compliance Plan Published February 23, 1998 Supplemental Guidance: January 31, 2005 False or Fraudulent Cost
More informationTAX COMPLIANCE AGREEMENT. Dated as of May 1, Between the CITY OF BRENTWOOD, MISSOURI. and. UMB BANK, N.A., as Trustee
GILMORE & BELL, P.C. DRAFT 1 APRIL 1, 2015 FOR DISCUSSION PURPOSES ONLY TAX COMPLIANCE AGREEMENT Dated as of May 1, 2015 Between the CITY OF BRENTWOOD, MISSOURI and UMB BANK, N.A., as Trustee $[Principal]
More informationPOST-ISSUANCE COMPLIANCE: HOW TO AVOID SEC AND IRS PROBLEMS
POST-ISSUANCE COMPLIANCE: HOW TO AVOID SEC AND IRS PROBLEMS Illinois Community College Chief Financial Officers October 17, 2013 Presented by: William L. Hirata, Esq., General Counsel Learning Objectives
More informationEl Paso County Hospital District d/b/a University Medical Center of El Paso A Component Unit of El Paso County, Texas Auditor s Report and Financial
Auditor s Report and Financial Statements Contents Independent Auditor s Report on Financial Statements and Supplementary Information... 1 Management s Discussion and Analysis... 4 Financial Statements
More information