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MT WHY?: How a Master Trust Indenture Can Simplify Your Life

USA - January 11 2019 Master Trust Indentures or “MTIs” have historically been implemented by hospitals and health systems as a way to pool the credit of multiple entities...

Jerimi J. Ullom.

The End of 97-13: IRS Releases New Safe Harbor for Private Business Use Resulting from Management and Service Contracts

USA - August 29 2016 On August 23, 2016, the IRS released Revenue Procedure 2016-44 (the "New Rev. Proc.") regarding safe harbors for avoidance of private business use for...

Jerimi J. Ullom.

The End of 97-13: IRS Releases New Safe Harbor for Private Business Use Resulting from Management and Service Contracts

USA - August 29 2016 On August 23, 2016, the IRS released Revenue Procedure 2016-44 (the “New Rev. Proc.”) regarding safe harbors for avoidance of private business use...

Jerimi J. Ullom.

IRS revises tax-exempt bond regulations for increased flexibility of equity allocations and creation of joint ventures with for-profit entities

USA - November 20 2015 On October 27, 2015, the IRS released final allocation and accounting regulations for tax-exempt bonds (the "New Regulations"). The New Regulations...

Jerimi J. Ullom.

Private use overhaul: IRS expands Rev. Proc. 97-13 safe harbors; provides guidance for participation in ACOs

USA - October 27 2014 On Friday, October 24, 2014, the IRS released an advance version of Notice 2014-67, (1) adding a new 5-year safe harbor to Revenue Procedure 97-13...

Jerimi J. Ullom.