The Law of Tax-Exempt Healthcare Organizations 2017 Cumulative Supplement, Fourth Edition + website

CHAPTER TWENTYHealthcare Provider Reorganizations

1. § 20.1 Some Basics about Reorganizations

§ 20.1 SOME BASICS ABOUT REORGANIZATIONS

p. 448. Insert footnote at the end of the second paragraph:

1. 9.1 Indeed, even healthcare providers sometimes grow weary of cumbersome organizational structures. In Priv. Ltr. Rul. 201445015, the IRS considered a request for rulings regarding a merger of a parent corporation, a nursing home, and a management services company back into their affiliated hospital. The purpose of the merger was to simplify organizational and governance structures, thereby creating more effective oversight by the hospital board of directors. The IRS ruled that this “de‐organization” would not adversely affect the charitable tax‐exempt status of the hospital as the surviving corporation, or its non–private foundation status as an organization described in IRC § 170(b)(1)(A)(iii).