OIG issues Special Fraud Alert on business arrangements with physician-owned entities *

USA - April 12 2013
On March 26, the HHS Office of Inspector General (OIG) issued a Special Fraud Alert (Fraud Alert) reiterating its long-standing concern that the…

Co-authors: Richard J Zall, Ellen H Moskowitz, Edward S Kornreich, Malcolm J Harkins, III, Herschel Goldfield.

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New York State agencies again revise proposed regulations limiting use of state funds for administrative expenses and executive compensation by service providers as of July 1, 2013 *

USA - April 8 2013
Implementing Executive Order 38 issued by Governor Cuomo early in 2012, thirteen New York State agencies have again released revised proposed…

Co-authors: Michael S Sirkin, Andrew Merten, Edward S Kornreich.

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Sixth Circuit will not rehear quality stores decision that severance pay in connection with a reduction in force is not subject to FICA; Supreme Court next step? *

USA - January 16 2013
On September 7, 2012, the Sixth Circuit Court of Appeals held in United States v. Quality Stores, Inc. that severance payments to former employees…

Co-authors: Andrea S Rattner, Paul M Hamburger.

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IRS imposes 27-month deadline for filing exemption applications for all types of exempt organizations seeking retroactive recognition of exemption and denies retroactive recognition of exemption if Forms 990 not filed *

USA - January 10 2013
The IRS continues to implement the "three years and you're out" rule for Form 990 non-filers added by the Pension Protection Act of 2006 (the "PPA"). That…

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Revised proposed New York regulations limit use of state funds for administration expenses and executive compensation by service providers as of April 1, 2013 *

USA - January 8 2013
Implementing Executive Order 38 issued by Governor Cuomo early in 2012, thirteen New York State agencies have now released revised proposed regulations…

Co-authors: Michael S Sirkin, Andrew Merten, Edward S Kornreich.

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