The Internal Revenue Service today issued Notice 2014-67, a copy of which is linked below. This Notice provides long-awaited guidance on the extent to which private business use of a tax-exempt bond-financed facility results from participation in an accountable care organization. This Notice also amplifies existing guidance under Revenue Procedure 97-13 regarding the types of management contracts that do not give rise to private business use of a tax-exempt bond-financed facility. After we’ve carefully reviewed and reflected on the Notice, we will post a more detailed analysis of it.

IRS Notice 2014-67