Non profit debt consolidation reviews

SummaryThe recently released final regulations under Internal Revenue Code Section 385, addressing the circumstances under which related company debt will be classified as equity for federal income tax purposes, will have a significant impact on state and local taxes. Federal tax practitioners, as well as state and local tax practitioners, must address their implications.In DepthThe US Department of the Treasury has just released final regulations under Section 385 of the Internal Revenue Code dealing with the circumstances under which related company debt will be classified as equity for income tax purposes. Regulations under this provision had been proposed in April 2016. The proposed regulations caused considerable consternation in the corporate taxpayer community. Although Section 385, which was enacted in the Tax Reform Act of 1969, arguably was intended merely to require Treasury to list factors that would be taken into account in determining when purported debt should be … [Read more...] about State and Local Tax Implications of Final Section 385 Debt-Equity Regulations

Hospital transactions involve complex processes and carry significant ramifications for an institution and the communities it serves.  This article outlines key steps that a hospital board and management team should take in order to develop a hospital transaction strategy.  Developing objectives early and conducting an options assessment will lead to a well-designed process that will facilitate an effective transaction.Pursuing a transaction is among the most significant actions that a hospital board and management team can undertake in the life of an institution.  It also is the riskiest.  Economic and non-economic stakes are high, including preserving the hospital’s mission and charitable objectives, safeguarding access to care, ensuring quality and protecting employees.  A well-run merger process maximizes board objectives and avoids critical missteps.This article identifies the key components of an effective transaction process.  Successful … [Read more...] about Hospital and Health System M&A Series: Developing a Hospital Transaction Strategy and Process

I. IntroductionThis article is the first of our new series regarding common issues and opportunities associated with combined reporting. Because most states either statutorily require or permit some method of combined reporting, it is important for taxpayers to understand the intricacies of and opportunities in combined reporting statutes and regulations.In this article, we will explore the foundation for combined reporting — the unitary business principle. The unitary business principle finds its roots in 19th-century property taxation, when the U.S. Supreme Court first observed that an integrated business should be taxed as one unit instead of separately accounting for its component parts.The unitary business principle plays an important role not only as a criterion for combined reporting, but also as a touchstone for a state’s ability to tax extraterritorial values. The application of the unitary business principle in the combined reporting context can be fairly … [Read more...] about Decoding Combination: What Is a Unitary Business

As with any market, supply and demand are key to price. Recently, nowhere else has this been seen more acutely than in the oil & gas markets. Headlines at the turn of the year were dominated by the fall in oil prices. Brent crude remains at around US$58 a barrel, down from US$100-120 only last summer. So, four months on from OPEC’s decision (in November 2014) not to cut supply in the face of reducing global demand and increased non-OPEC production, how have companies in the oil sector fared?Up pipeThose with deep pockets will obviously fare better than others. Whilst the major oil & gas companies have cut back on exploration, staff and capital expenditure, oil price volatility is not new to them and these companies are generally used to weathering and planning for such storms. Equally, however, oil & gas companies are keen overall not to stop new investment or let skilled staff go. Previous downturns have shown this to be a poor strategy for the medium turn but it … [Read more...] about Coming Down the Pipeline: Risk and Opportunity for Oil and Gas Sector in Era of Low Oil Prices

Regulatory bodies and lawsAviation in the United States is regulated primarily by the Department of Transportation and the Federal Aviation Administration (FAA) pursuant to Title 14 of the Code of Federal  Regulations (the Federal Aviation Regulations, 49 USC (the Transportation Code) and  the corresponding regulations.Safety regulationThe FAA regulates the safety of commercial and private air transport. Screening passengers and ensuring onboard security is the responsibility of the Department of Homeland Security's Transportation Security Administration. The National Transportation Safety Board conducts non-criminal aircraft accident investigations.The Federal Aviation Regulations (14 CFR Section 1.1) define a 'commercial operator' as:"A person who, for compensation or hire, engages in the carriage by aircraft in air commerce of persons or property... [W]here it is doubtful that an operator is for 'compensation or hire', the test applied is whether the carriage by air is … [Read more...] about Regulation of Aviation Operations