Exempt Organizations

Recognizing that a large segment of the health care industry consists of tax-exempt organizations, we have extensive experience in advising tax-exempt health care clients on a variety of federal income tax matters. Specifically, our attorneys have assisted tax-exempt health care systems and their affiliated hospitals, foundations, physician organizations and other affiliates in connection with:

  • Applying for and obtaining tax-exempt status
  • Avoiding impermissible inurement and private benefit
  • Reclassifying tax-exempt and public charity status
  • Analyzing unrelated business income tax issues
  • Ensuring compliance with tax-exempt bond requirements
  • Structuring joint ventures with taxable entities
  • Complying with political campaign prohibitions and lobbying limitations
  • Implementing best practices governance structures
  • Advising on business transactions, employment arrangements, corporate restructurings, and IRS and state and local tax audits

Section 501(c)(3) hospitals face additional tax-exemption requirements under Section 501(r) of the Internal Revenue Code, and our health care attorneys monitor ongoing Section 501(r) developments and assist clients in connection with structuring compliant policies and procedures.