Federal Law Update: Ancillary Joint Ventures After ... - Honigman

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Revenue Sharing Arrangements • Effective only after final Regs. are issued • Currently FMV limit applies • Facts and Circumstances Test: – proportionate benefit to EO and DP – relationship to quality and quantity of services – control of activities generating the revenues • No mention of a “cap” -- still helpful • Potentially affects all joint ventures
Ancillary Joint Ventures •Two-prong Test • Rev. Rul. 98-15/Redlands – Management Contracts – Expanded Control Test – Community Benefit • Exemption Impact of 50/50 Ventures • Unwinding Joint Ventures • Other Structuring Options
Page 1 and 2: Federal Law Update: Ancillary Joint
Page 3 and 4: Areas not addressed • Non-tax con
Page 5 and 6: Audit Activity • Ongoing joint ve
Page 7 and 8: Defining “Insiders” • No Free
Page 9: TBOR2 Basics • Two-tier tax on di
Page 13 and 14: Typical Whole Hospital Joint Ventur
Page 15 and 16: Ancillary Services Joint Venture (H
Page 17 and 18: Redlands Community Hospital Foundat
Page 19 and 20: Redlands: Why Not Exempt? • Sole
Page 21 and 22: Redlands: Why Not Exempt? • RSS w
Page 23 and 24: Expanded Control Test • Initiatio
Page 25 and 26: Community Benefit •New services
Page 27 and 28: Exemption Impact of 50/50 Ventures
Page 29 and 30: Other Structuring Options • Taxab
Page 31: Non-tax Considerations • Antifrau

Federal Law Update: Ancillary Joint Ventures After ... - Honigman

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