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

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Other Structuring Options • Insubstantial portion of activities--UBI only – No joint ventures with insiders – IRS favorably inclined, no rulings pending appeal • not involve substantially all assets • reverse one or more bad facts of Rev. Rul. 98- 15/Redlands (e.g., charity care and Medicaid at same levels as hospital, independent management company with a more reasonable contract) • unclear how many “bad facts” must become “good facts”
Non-tax Considerations • Antifraud Statute – Gainsharing Special Advisory Bulletin (reference to clinical joint ventures) – New safe harbors: 64 Fed. Reg. 63517 (Nov. 19, 1999) •Stark <strong>Law</strong> • Indenbaum/16221 (“Stark on steroids”) • Antitrust
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 and 10: TBOR2 Basics • Two-tier tax on di
Page 11 and 12: Ancillary Joint Ventures •Two-pro
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: Other Structuring Options • Taxab

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

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