Michael G. Bailey

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On November 2, 2017, the “Tax Cuts and Jobs Act” was introduced in the House of Representatives. This act has immediate and far-reaching implications for tax-exempt finance. Among other things, the Tax Cuts and Jobs Act would: Repeal the authority to issue “qualified private activity bonds” after December 31, 2017. These bonds generally include all tax-exempt bonds that are not “governmental bonds,” and include tax-exempt bonds issued for the benefit of 501(c)(3) organizations…
The U.S. Treasury Department and Internal Revenue Service published final regulations on October 27, 2015 concerning the treatment of “mixed-use” projects financed with tax-exempt bonds. These new regulations have particular importance for tax planning and tax compliance of 501(c)(3) health care organizations that are borrowers of tax-exempt bonds.…
The IRS released guidance at the end of 2013 that is helpful for tax-exempt hospitals in complying with the detailed additional federal tax requirements set forth in section 501(r) of the Internal Revenue Code. The guidance (1) sets forth specific proposed procedures for correcting and disclosing instances of failure to comply with the requirements and (2) clarifies that organizations can use alternative provisions in proposed regulations as safe harbors until final guidance is published. Section…