Tax planning for noncorporate bankruptcies
Article Abstract:
Noncorporate taxpayers or their advisers need to be aware of bankruptcy law, tax consequences of bankruptcy filings and have clear goals to complete a bankruptcy filing with no remaining tax liabilities. Some of the situations resulting in adverse tax consequences include the creation of cancellation of debt income, abandonment of property by the bankruptcy estate and tax attribute transfers between the estate and taxpayer. Some planning alternatives include retaining favorable tax attributes, shifting tax liabilities to the estate and the use of pension plans.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1992
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The IRS's whole hospital joint venture ruling: guidance or confusion?
Article Abstract:
IRS Revenue Ruling 98-15 provides guidance regarding the effect on the IRC section 501(c)(3) tax-exempt status of hospitals which form limited liability companies which engage in joint ventures with for-profit business entities. Whole-hospital limited liability companies in particular were addressed in the ruling which was issued on Mar 4, 1998. The reach of the ruling is unclear. Concern exists regarding issues such as the ruling's application to ancillary services directly engaged in by hospitals operating in joint venture structures.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1998
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IRS attacks hospital joint ventures
Article Abstract:
The IRS's General Counsel Memorandum 39862 raises the issue of whether hospitals that enter into joint ventures with physicians can retain their tax-exempt status. Hospitals previously have been able to remain tax-exempt by not operating in a way that benefits shareholders or private interests. The IRS has reconsidered its stance, stating that private interests are receiving more than incidental benefits from these joint ventures.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1992
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