Often in healthcare transactions, retaining a federal Employer Identification Number (“EIN”) after an acquisition or restructuring is essential to the continuity of operations, regulatory compliance, and preservation of key...more
Plan sponsors of Code Section 403(b) tax-sheltered annuity plans (“403(b) plans”) that have not already done so may want to consider applying for an IRS determination letter or planning and budgeting for the process next year...more
Physician recapitalization transactions are complex by nature and often present myriad issues. At Foley, in our representation of both investors in, and sellers of, physician practices, we note how often tax issues become...more
In Revenue Procedure 2022-40, the IRS recently expanded the determination letter program to allow applications by individually-designed 403(b) plans. This expansion will allow 403(b) plan sponsors to request a determination...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 6 – 10, 2019. May 7, 2019: The IRS released Revenue Procedure 2019-22 updating Revenue...more