This session will discuss the health system implications of the latest tangible property regulations, implementation of the medical device excise tax and ACT recommendations on Form 1023.
Businesses and governments face many political risks. Understanding of these risks helps in managing them in a better way. http://i-strategic.com/ highlights some of the most common political risks.
the political economy of international trade
,
instrument of trade policy
,
what is the political reality of international tr
,
how has the current world trading system emerged
,
what is the future of the world trade organization
,
what do trade barriers mean for managers
,
how do governments intervene in markets
,
why government intervene
,
3:import quota
On November 30, 2016, Alan Ellenby and Ron Krupa of Ernst & Young LLP's Workforce Advisory Services provided tips and insights on reporting and compliance under the Affordable Care Act for year-end 2016. This topic was one of many covered in in Ernst & Young LLP's Employment Tax Year in Review webcast.
Here we share with you the slides from their presentation.
Businesses and governments face many political risks. Understanding of these risks helps in managing them in a better way. http://i-strategic.com/ highlights some of the most common political risks.
the political economy of international trade
,
instrument of trade policy
,
what is the political reality of international tr
,
how has the current world trading system emerged
,
what is the future of the world trade organization
,
what do trade barriers mean for managers
,
how do governments intervene in markets
,
why government intervene
,
3:import quota
On November 30, 2016, Alan Ellenby and Ron Krupa of Ernst & Young LLP's Workforce Advisory Services provided tips and insights on reporting and compliance under the Affordable Care Act for year-end 2016. This topic was one of many covered in in Ernst & Young LLP's Employment Tax Year in Review webcast.
Here we share with you the slides from their presentation.
Kegler Brown global business attorneys Luis Alcalde and David Wilson presented " Exporting from the United States: Key Legal Considerations" at the 2014 Ohio Export Internship Program.
They discussed international trade in a legal context, international trading or transfers, due diligence, FCPA and why compliance is important.
Insurance health plans and the ACA Section 9010 Annual FeeEY
Understand the federal income tax status of existing and new Section 501(c)(3) and Section 501(c)(4) HMOs, and the structure of the ACA Section 9010 fee on health insurance providers.
Kegler Brown global business attorneys Luis Alcalde and David Wilson presented " Exporting from the United States: Key Legal Considerations" at the 2014 Ohio Export Internship Program.
They discussed international trade in a legal context, international trading or transfers, due diligence, FCPA and why compliance is important.
Insurance health plans and the ACA Section 9010 Annual FeeEY
Understand the federal income tax status of existing and new Section 501(c)(3) and Section 501(c)(4) HMOs, and the structure of the ACA Section 9010 fee on health insurance providers.
Chapter1Introduction to Federal Taxation and Understanding theJinElias52
Chapter
1
Introduction to Federal Taxation and Understanding the Federal Tax Law
OBJECTIVES
After completing Chapter 1, you should be able to:
1. Identify types of taxes used by federal and state governments to raise revenues.
2. Understand the methods of tax collection and the trends shown by tax collection statistics.
3. Differentiate between tax avoidance and tax evasion.
4. Recall the underlying rationale of the federal income tax and its historical development.
5. Describe the route a tax bill takes until enacted into law.
6. Define the basic tax concepts and terms of federal income taxation.
INTRODUCTION
Federal taxation is the fuel by which Americans power their “Ship of State.” The tax structure which supports our federal government has gone from quill and ink records of revolutionary assessments to lightning speed computers which calculate and validate millions of income tax returns submitted by individuals and corporations. Federal taxes, in addition to the income tax, include a variety of other taxes covering estates, gifts, and customs, as well as excise taxes, and other minor categories of tax. Our governments can thus select among a variety of tax alternatives to produce the revenues required to operate national programs and carry out national policies.
Taxes are big business. Unfortunately, many business decisions are made in the United States today without regard to federal tax consequences. Individuals are concerned with personal income tax decisions and gift and estate tax decisions, while corporations concern themselves with corporate taxes, personal holding company taxes, and accumulated earnings tax decisions. Further, businesspersons must concern themselves with the choice of business entity: corporation, partnership, or S corporation. Differences in tax costs can be considerable. Advantages and disadvantages are virtually unlimited. This book presents information which is required knowledge if you make business decisions.
While most businesspersons (and many advisors) think about how to make decisions in nontax terms, the tax accountant bears the burden of introducing tax considerations. The topics presented in this book must be viewed in terms of decision-making—therefore, tax planning and tax research are of the utmost importance. Tax decisions are not made in a vacuum. Lawyers, accountants, financial managers, and a host of other experts work as a team in the decision-making process. This book is intended to serve as a guide for accounting students and for MBA students interested in gaining insight into and expertise in the tax complexities of business decision-making.
OVERVIEW
This chapter presents information on the magnitude of federal taxes collected and on taxpayer obligations. Then, a brief historical account is presented of federal tax collections prior to and after the adoption of the Sixteenth Amendment to the Constitution, which enabled Congress to levy “taxes on incomes, from whatever source derived.” Foll ...
Global companies investing in the United States face unique opportunities and challenges. Doing business in the US reviews the key tax issues and provides insights to help investors navigate the US business environment.
See how firms in the device industry have met the tax and compliance challenges of the Medical Device Excise Tax, which goes into effect January 1, 2013.
Startup Basics: Money People and TechnologyRoger Royse
The Royse Law firm offers significant advise that early stage startups should ensure they understand. The slides contain great considerations that startups should utilize. Our team is a full service firm that provides legal counseling to many startups. Please contact us so we can help you ensure the health of your startup. (01/2018)
Doing business in an international context can be daunting. WeiserMazars serves as a bridge between the United States and the global markets, making doing business easier and less risky for our clients. We connect overseas clients with American professionals and service the tax, transaction services and financial reporting needs of foreign entities based in the U.S.
The theme for this quarter is momentum meets uncertainty. The upward trend in crude oil, natural gas, LNG and refined product prices that began in Q1 continued into Q2. Crude oil markets began the quarter just below $100/bbl and have closed below that level on only two days since late April. As we begin Q3, there are increasing concerns about the health of the global economy and how that might affect oil and gas demand.
Quarterly analyst themes of oil and gas earnings, Q1 2022EY
Financial questions continued to attract the most attention of the analyst community, with major focus on how companies will respond to the war in Ukraine, elevated commodity prices and improved cash flows. Strategic questions focused on how the changing geopolitical environment will affect capital allocation in the short and long term. Operationally, all eyes were on the capacity of companies to step up asset utilization and bring new projects to market quickly. Explore the latest EY quarterly analysts themes.
EY Price Point: global oil and gas market outlook, Q2 | April 2022EY
The theme for this quarter is rearrangement. The loss, or potential loss, of Russian oil and gas supplies is forcing producers, refiners and traders to rethink the flow of crude oil and refined products from the wellhead to the gas pump in light of sanctions, potential sanctions and the risk of reputational damage. Countries, companies and consumers will all be searching for ways to adapt, and the outcome of the race to bring alternatives to market could alter the global energy landscape for years to come.
It is likely crude oil and LNG prices will remain elevated for some time. The process of diverting Russian oil through countries unwilling to sanction it will take time and there is little indication OPEC members are willing (or able) to increase production to make up for the loss of Russian crude. Spare capacity sat at 3.7 mbpd at the end of 2021, just above where it was in January 2020. Currently, sanctioned Venezuelan and Iranian production (about 3 mbpd below their peak) could fill the gap, but political and commercial obstacles remain. At today’s prices, US shale production is attractive, but the fastest the industry has been able to grow is between 1mbpd and 2mbpd per year. The LNG infrastructure was already stretched before the war in Ukraine and there is little prosect of finding new supplies soon.
As the largest buyer of Russian energy, Europe will be the epicenter. There is a deeply embedded bias there in favor for renewable energy, and the current crisis is certain to result in an all-out effort to accelerate the build-out of wind and solar power. The capacity to add new green energy is limited though by the project pipeline and supply chains for solar panels and wind turbines, and it is likely that much of the shortfall will be made up with the new LNG infrastructure.
EY Price Point: global oil and gas market outlookEY
As the last quarter of the second pandemic year draws to a close, we continue to see heightened contrast
between the medical and economic points of view. While COVID-19 cases are close to their all-time highs, so
are equity prices, and a leading investment bank declared (on 2 December, 2021 after the Omicron outbreak in South Africa) that it was “optimistic about the possibility of a vibrant 2022.” When news of the variant hit in
late November, the markets were rocked by the prospect of yet another round of local mobility restrictions and
an interrupted return to normal international travel patterns, on top of the Biden Administration’s announced
release of 50 million barrels of crude from the US Strategic Petroleum Reserve. So far though, with OPEC
standing by its planned gradual return to normal production, oil prices have stabilized, albeit below where they
were in mid-November. Henry Hub prices, always at the mercy of the weather, responded predictably to a
warmer-than-normal early winter in the US, falling from US$6.60/MMBtu in early October to below
US$4.00/MMBtu by mid-December. In Europe and Asia, following a short reprieve at the start of the quarter,
piped natural gas prices have spiked again on concerns triggered by Russian troop buildups on the Ukraine
border and uncertainties surrounding the Nordstream 2 pipeline. Looking forward, OPEC and the U.S. Energy
Information Administration (EIA) in their last forecasts of the year both projected that 2022 oil demand would
be above what we saw in 2019. Although time will tell if those forecasts are realized and other events could
intervene, the response to new virus outbreaks is well-practiced and the trade-off between public health and
economic reality has tipped toward a cautiously optimistic view.
EY Price Point: global oil and gas market outlook, Q2 April 2021EY
The theme for this quarter is governed. Apparent market balance at prices that could be sustainable is the product of calculated choices by market leaders and the cooperation of those who follow them. Economics played their customary role as well, with capital scarcity in North America taking about 2 million barrels per day out of the market, about half of the remaining gap in demand. While inventories are close to their pre-COVID-19 levels, there is still uncertainty. The resolution of the pandemic is in sight, but timing is unclear. Vaccine distribution in the US is having an impact but Europe is struggling to contain a third wave of infections. The taps have opened on economic stimulus, but it remains to be seen if policymakers have done enough or if they have overshot the mark.
The shape of the crude oil forward curve has fundamentally changed since the end of the last quarter. In late December of last year, the Brent forward curve was gradually increasing while today, the curve is backwardated. This is a clear sign that the market sees a short-term dynamic that is disconnected from the medium-to-long-term fundamentals. The lasting impact of the COVID-19 pandemic remains to be seen. While many have opined that COVID-19 marks a turning point in energy transition, the IEA recently released a five-year forecast of oil demand that shows steady growth, albeit at rates that are below historical expectations.
Gas markets are a paradox. At the Henry Hub and at LNG destinations, demand grows, investment lags and prices will occasionally attract attention. Traders, so far though, are unconvinced and futures prices don’t indicate imminent scarcity at any link in the value chain.
EY Price Point: global oil and gas market outlookEY
We enter 2021 on a note of cautious optimism for global health, the world economy, and the oil and gas markets. The first weeks of December brought approval in the US and the UK of the first of several COVID-19 vaccines. The speed with which vaccine development occurred is unprecedented, but certainly welcome. In the weeks following the early November announcement of 90+% effectiveness by the manufacturer of the first approved vaccine, the price of WTI crude oil increased by US$10/bbl to US$48/bbl, the highest level since early March. Sustainability hasn’t returned yet, and whatever time it takes to get the world to normal, it will take even longer for normalization within the oil and gas markets. Inventories remain at historically high levels and, optimistically, it will take until April before inventory returns to levels observed in the preceding five years. That’s an estimate, and there has obviously been some difficulty properly calibrating the expectations of how balance will return and how long it will take. In late November, OPEC met to adjust its output plans because of the anemic rebound in demand. In mid-December, the IEA lowered its demand forecast for 2021 due mostly to continued sluggishness in aviation fuel demand.
A mild winter has interrupted a recovery in North American natural gas prices after a run-up motivated by curtailed capital expenditures, upstream activity and production. After an initial meltdown, with cargo cancellations and dramatic price reversal, LNG markets have made a remarkable comeback, and the spread between Asia and Henry Hub has reached a level we haven’t seen in almost three years. It may be the case that interruption in FIDs has brought us to the cusp of a balance that can support reliable returns.
EY Price Point: global oil and gas market outlook (Q4, October 2020)EY
Oil and gas prices have recovered steadily from their lows and are relatively stable, but that stability is supported by the combination of purposeful withholding of production by oil-producing countries and economic stress on upstream independents. Oil prices closed the quarter roughly where they started it, while refining spreads were down slightly. LNG spreads were substantially higher at the end of Q3 than they were at the beginning of the quarter but are still roughly half of what is generally thought of as sustainable.
Going forward, the market will be looking closely at how the economy and demand respond to new developments with respect to a potential COVID-19 vaccine and the US election.
EY Price Point: global oil and gas market outlookEY
As we close the second quarter of 2020, in most of Europe and Asia, the first (and hopefully last) wave of the COVID-19 crisis appears to be abating. In the parts of the US where the virus hit early, the profile has largely matched Europe’s, while in other parts, the urge to reopen businesses has trumped the desire to contain the virus and uncertainty looms. In the developing world, the crisis has just begun, but without the economic headroom and resources necessary to contain it. As the crisis unfolded, the effect on oil and gas demand has been predictable but difficult to gauge precisely and therefore difficult to manage.
Oil prices have crept up steadily as production has been curtailed through coordinated action (OPEC+) and because of economic reality (unconventional oil in North America). That trend has been subject to momentary spasms when bad news hit the market. It would be understandable if traders were nervous, and it seems that they are. Although nowhere near where it was at the peak of the crisis, option implied volatility is still at historically high levels. Gas markets, without the benefit of coordination on the supply side, continue to deal with the market implications of storage at or near capacity. Interfuel competition in power generation has always provided something of a floor, but those lows have been, and will continue to be, tested.
Zahl der Gewinnwarnungen steigt auf RekordniveauEY
Immer mehr deutsche börsennotierte Unternehmen müssen ihre eigenen Umsatz- oder Gewinnprognosen nach unten korrigieren. Im ersten Quartal stieg die Zahl der Prognosekorrekturen auf ein neues Rekordniveau: Insgesamt 77 Gewinn- oder Umsatzwarnungen wurden registriert.
Die Corona-Krise trifft auch die Versicherungsbranche mit voller Wucht. Die Versicherer rechnen mit weniger Neugeschäft. Jeder Fünfte mit Personalabbau und Prämienerhöhungen.
Liquidity for advanced manufacturing and automotive sectors in the face of Co...EY
With a global economy in crisis due to Covid-19 our liquidity and cash management deck for advanced manufacturing and
mobility companies looks at how these companies should best respond.
IBOR transition: Opportunities and challenges for the asset management industryEY
EY Wealth & Asset Management explores the practical implications and the way forward for the transition to the new risk-free rates. This presentation aims to help asset managers and asset owners explore IBOR transition strategies that are compliant and future-focused.
Fusionen und Übernahmen dürften nach der Krise zunehmenEY
Folgt auf die Corona-Krise ein M&A-Boom? Laut Capital Confidence Barometer von #EY hoffen 40 Prozent der deutschen Unternehmen auf sinkende Bewertungen von Übernahmekandidaten.
EY Price Point: global oil and gas market outlook, Q2, April 2020EY
The first quarter of this year has seen some extraordinary events. As if chronic oversupply, prices stuck below sustainable levels, the looming energy transition, and investor pressure to decarbonize weren’t enough, our industry now faces a dramatic, but hopefully temporary, downturn in demand as a result of the ongoing COVID-19 outbreak.
Our Global Chemical Industry Leader Frank Jenner explores the trends and drivers that will shape the chemical industry of tomorrow in our latest Chemical Market Outlook.
Die Geschäftslage im Mittelstand hat sich leicht verschlechtert, ist in den meisten Branchen aber weiter überwiegend gut - die Einstellungsbereitschaft sinkt.
Seminar: Gender Board Diversity through Ownership NetworksGRAPE
Seminar on gender diversity spillovers through ownership networks at FAME|GRAPE. Presenting novel research. Studies in economics and management using econometrics methods.
BONKMILLON Unleashes Its Bonkers Potential on Solana.pdfcoingabbar
Introducing BONKMILLON - The Most Bonkers Meme Coin Yet
Let's be real for a second – the world of meme coins can feel like a bit of a circus at times. Every other day, there's a new token promising to take you "to the moon" or offering some groundbreaking utility that'll change the game forever. But how many of them actually deliver on that hype?
What website can I sell pi coins securely.DOT TECH
Currently there are no website or exchange that allow buying or selling of pi coins..
But you can still easily sell pi coins, by reselling it to exchanges/crypto whales interested in holding thousands of pi coins before the mainnet launch.
Who is a pi merchant?
A pi merchant is someone who buys pi coins from miners and resell to these crypto whales and holders of pi..
This is because pi network is not doing any pre-sale. The only way exchanges can get pi is by buying from miners and pi merchants stands in between the miners and the exchanges.
How can I sell my pi coins?
Selling pi coins is really easy, but first you need to migrate to mainnet wallet before you can do that. I will leave the telegram contact of my personal pi merchant to trade with.
Tele-gram.
@Pi_vendor_247
where can I find a legit pi merchant onlineDOT TECH
Yes. This is very easy what you need is a recommendation from someone who has successfully traded pi coins before with a merchant.
Who is a pi merchant?
A pi merchant is someone who buys pi network coins and resell them to Investors looking forward to hold thousands of pi coins before the open mainnet.
I will leave the telegram contact of my personal pi merchant to trade with
@Pi_vendor_247
Financial Assets: Debit vs Equity Securities.pptxWrito-Finance
financial assets represent claim for future benefit or cash. Financial assets are formed by establishing contracts between participants. These financial assets are used for collection of huge amounts of money for business purposes.
Two major Types: Debt Securities and Equity Securities.
Debt Securities are Also known as fixed-income securities or instruments. The type of assets is formed by establishing contracts between investor and issuer of the asset.
• The first type of Debit securities is BONDS. Bonds are issued by corporations and government (both local and national government).
• The second important type of Debit security is NOTES. Apart from similarities associated with notes and bonds, notes have shorter term maturity.
• The 3rd important type of Debit security is TRESURY BILLS. These securities have short-term ranging from three months, six months, and one year. Issuer of such securities are governments.
• Above discussed debit securities are mostly issued by governments and corporations. CERTIFICATE OF DEPOSITS CDs are issued by Banks and Financial Institutions. Risk factor associated with CDs gets reduced when issued by reputable institutions or Banks.
Following are the risk attached with debt securities: Credit risk, interest rate risk and currency risk
There are no fixed maturity dates in such securities, and asset’s value is determined by company’s performance. There are two major types of equity securities: common stock and preferred stock.
Common Stock: These are simple equity securities and bear no complexities which the preferred stock bears. Holders of such securities or instrument have the voting rights when it comes to select the company’s board of director or the business decisions to be made.
Preferred Stock: Preferred stocks are sometime referred to as hybrid securities, because it contains elements of both debit security and equity security. Preferred stock confers ownership rights to security holder that is why it is equity instrument
<a href="https://www.writofinance.com/equity-securities-features-types-risk/" >Equity securities </a> as a whole is used for capital funding for companies. Companies have multiple expenses to cover. Potential growth of company is required in competitive market. So, these securities are used for capital generation, and then uses it for company’s growth.
Concluding remarks
Both are employed in business. Businesses are often established through debit securities, then what is the need for equity securities. Companies have to cover multiple expenses and expansion of business. They can also use equity instruments for repayment of debits. So, there are multiple uses for securities. As an investor, you need tools for analysis. Investment decisions are made by carefully analyzing the market. For better analysis of the stock market, investors often employ financial analysis of companies.
Turin Startup Ecosystem 2024 - Ricerca sulle Startup e il Sistema dell'Innov...Quotidiano Piemontese
Turin Startup Ecosystem 2024
Una ricerca de il Club degli Investitori, in collaborazione con ToTeM Torino Tech Map e con il supporto della ESCP Business School e di Growth Capital
2. Elemental Economics - Mineral demand.pdfNeal Brewster
After this second you should be able to: Explain the main determinants of demand for any mineral product, and their relative importance; recognise and explain how demand for any product is likely to change with economic activity; recognise and explain the roles of technology and relative prices in influencing demand; be able to explain the differences between the rates of growth of demand for different products.
Lecture slide titled Fraud Risk Mitigation, Webinar Lecture Delivered at the Society for West African Internal Audit Practitioners (SWAIAP) on Wednesday, November 8, 2023.
how to sell pi coins effectively (from 50 - 100k pi)DOT TECH
Anywhere in the world, including Africa, America, and Europe, you can sell Pi Network Coins online and receive cash through online payment options.
Pi has not yet been launched on any exchange because we are currently using the confined Mainnet. The planned launch date for Pi is June 28, 2026.
Reselling to investors who want to hold until the mainnet launch in 2026 is currently the sole way to sell.
Consequently, right now. All you need to do is select the right pi network provider.
Who is a pi merchant?
An individual who buys coins from miners on the pi network and resells them to investors hoping to hang onto them until the mainnet is launched is known as a pi merchant.
debuts.
I'll provide you the Telegram username
@Pi_vendor_247
how to sell pi coins in South Korea profitably.DOT TECH
Yes. You can sell your pi network coins in South Korea or any other country, by finding a verified pi merchant
What is a verified pi merchant?
Since pi network is not launched yet on any exchange, the only way you can sell pi coins is by selling to a verified pi merchant, and this is because pi network is not launched yet on any exchange and no pre-sale or ico offerings Is done on pi.
Since there is no pre-sale, the only way exchanges can get pi is by buying from miners. So a pi merchant facilitates these transactions by acting as a bridge for both transactions.
How can i find a pi vendor/merchant?
Well for those who haven't traded with a pi merchant or who don't already have one. I will leave the telegram id of my personal pi merchant who i trade pi with.
Tele gram: @Pi_vendor_247
#pi #sell #nigeria #pinetwork #picoins #sellpi #Nigerian #tradepi #pinetworkcoins #sellmypi
BYD SWOT Analysis and In-Depth Insights 2024.pptxmikemetalprod
Indepth analysis of the BYD 2024
BYD (Build Your Dreams) is a Chinese automaker and battery manufacturer that has snowballed over the past two decades to become a significant player in electric vehicles and global clean energy technology.
This SWOT analysis examines BYD's strengths, weaknesses, opportunities, and threats as it competes in the fast-changing automotive and energy storage industries.
Founded in 1995 and headquartered in Shenzhen, BYD started as a battery company before expanding into automobiles in the early 2000s.
Initially manufacturing gasoline-powered vehicles, BYD focused on plug-in hybrid and fully electric vehicles, leveraging its expertise in battery technology.
Today, BYD is the world’s largest electric vehicle manufacturer, delivering over 1.2 million electric cars globally. The company also produces electric buses, trucks, forklifts, and rail transit.
On the energy side, BYD is a major supplier of rechargeable batteries for cell phones, laptops, electric vehicles, and energy storage systems.
Analyzing the instability of equilibrium in thr harrod domar model
Top-of-mind issues for tax-exempt providers
1. 22nd Annual Health Sciences
Tax Conference
Top-of-mind issues for tax-exempt providers
December 3, 2012
2. Disclaimer
► Any US tax advice contained herein was not intended or
written to be used, and cannot be used, for the purpose of
avoiding penalties that may be imposed under the Internal
Revenue Code or applicable state or local tax law
provisions.
Page 2 Top-of-mind issues for tax-exempt providers
4. Presenters
► Tricia Johnson ► Felicia Tucker
Ernst & Young LLP Ernst & Young LLP
Cincinnati, OH Jericho, NY
+1 513 612 1850 +1 516 336 0362
tricia.johnson1@ey.com felicia.tucker@ey.com
Page 4 Top-of-mind issues for tax-exempt providers
5. Topics
► “Follow the money” and political/lobbying activities
► Medical device excise tax
► Advisory Committee on Tax Exempt and Government
Entities (ACT) recommendations on Form 1023
► Internal Revenue Service (IRS) Master File considerations
► Tangible property regulations
Page 5 Top-of-mind issues for tax-exempt providers
7. Political campaign activity
► Regarding a candidate
► Any activity that favors or opposes candidates for public
office, including:
► Endorsement of candidates
► Contributions
► To candidates
► To political action committees (PACs)
► Public statements for/against a particular candidate or favorable
activity toward or against a candidate
► Distributing materials prepared by oneself or others that favor or
oppose candidates
► All facts and circumstances will be considered
Page 7 Top-of-mind issues for tax-exempt providers
8. Lobbying
► Attempting to influence a piece of legislation
► Direct lobbying
► Directly contacting members of a legislative body
► Encouraging the public to contact members of a legislative body
► Advocating a position on a public referendum
► Grassroots lobbying
► The amount spent to influence, or an attempt to affect, the
opinions of the general public or any part of the general public
about an issue
Page 8 Top-of-mind issues for tax-exempt providers
9. General advocacy and educational activities
► Influence non-legislative governing bodies (e.g., the
executive branch or regulators)
► Encourage voter participation in a non-partisan manner
► Voter registration
► Get out the vote drives
► Voter guides
► Candidate debates
Page 9 Top-of-mind issues for tax-exempt providers
10. 501(c)(3) organizations
► Political campaign activity
► Prohibited, and may cause a loss of exemption
► Schedule C (Form 990) does allow a reporting of a correction
► Lobbying
► Must be an insubstantial activity of the organization
► Facts and circumstances test, and “insubstantial” is not defined
► Safe harbor — Section 501(h) election
► Up to US$1,000,000 direct expenditures and US$250,000 grassroots;
based on total exempt-purpose expenditures
► Applied on an affiliated group basis
► Excise tax for excess lobbying
► General advocacy
► Permitted as an educational activity
Page 10 Top-of-mind issues for tax-exempt providers
11. 501(c)(3) organizations — 501(h) election and
reporting requirements
► Safe harbor expenditure test
► Make election by filing Form 5768
► Affiliated group application
► Excise tax for exceeding non-taxable amount in any one year
► Loss of exemption if excessive over a four-year period
► May also un-elect
► Form 990, Part IV
► 3. Did the organization engage in direct or indirect political
campaign activities on behalf of or in opposition to candidates for
public office? If “Yes,” complete Schedule C, Part I.
► 4. Section 501(c)(3) organizations. Did the organization engage in
lobbying activities, or have a section 501(h) election in effect
during the tax year? If “Yes,” complete Schedule C, Part II.
Page 11 Top-of-mind issues for tax-exempt providers
12. 501(c)(4), (c)(5) or (c)(6) organizations
► Political campaign activity
► Permitted so long as it does not constitute the organization’s
primary activity
► Lobbying
► Unlimited amount of lobbying in furtherance of its exempt
purpose permitted
► General advocacy
► Unlimited amount in furtherance of its exempt purpose permitted
Page 12 Top-of-mind issues for tax-exempt providers
14. Medical device excise tax (MDET) —
imposition of tax
► Internal Revenue Code (IRC) Section 4191 imposes a
2.3% excise tax on:
► The “sale” or rental (or other first use) in the US
► Of “taxable medical devices”
► By a “manufacturer” or “importer”
► Effective January 1, 2013
► Proposed regulations were issued February 3, 2012
► While the comment period ended May 7, 2012, the IRS has asked
for additional comments from interested parties.
Page 14 Top-of-mind issues for tax-exempt providers
15. Which devices are taxable?
► Taxable medical devices are medical devices sold or used
in the United States and intended for use on humans.
► The Food and Drug Administration (FDA) listing includes
5,800+ separate devices.
► Manufacturers are required to list devices with the FDA.
► Hospitals may make some of the same items for internal use, but
are generally exempt from the FDA-listing requirements for those
items.
► To be taxable, medical devices must be:
► Listed with the FDA (i.e., have a three-letter FDA product code)
► Finished goods ready for the market
► Not otherwise qualified for an exemption
Page 15 Top-of-mind issues for tax-exempt providers
16. Which devices are exempt?
► Items not listed with a 3-letter FDA product code under FDA 510(k)
requirements
► Exports
► Eyeglasses, hearing aids and contact lenses
► Specific custom-fit items
► Items sold for further manufacturing
► Certain medical devices sold at retail
► Items not required to be listed with the FDA because they are sold
exclusively for use in “research”
► Investigational device exemption (IDE) — a medical device not yet
required to be listed with the FDA because the FDA has not yet
approved it for marketing
Page 16 Top-of-mind issues for tax-exempt providers
17. Determining the taxpayer
► MDET is imposed on the manufacturer, producer or importer of a taxable
article.
► For excise tax purposes, the term manufacturer includes a “producer” and
an “importer.”
► A manufacturer is a person who produces a taxable article by processing,
manipulating or changing the form of an article, or by combining or assembling two
or more articles.
► Because the MDET applies only to US sales of taxable medical devices, the
MDET is also imposed on importers in lieu of the
actual manufacturer.
► An “importer” of a taxable article is any person who brings an article into the US
from a source outside the US and is the beneficial owner.
► While the IRS has yet to issue any rulings on the medical device excise tax, they
have issued several rulings holding customers to be importers in situations where
taxable articles are imported directly from foreign manufacturers, even if there was
an agent or arranger of the sale involved.
Page 17 Top-of-mind issues for tax-exempt providers
18. Tax compliance and paying the liability
► Due by the manufacturer or importer
► Tax returns will be filed quarterly on the Form 720
► Estimated tax payments are due biweekly (every two weeks)
► First payment of the medical device excise tax is due January 28, 2013, for activity January 1–14
► Exemption certificates will be available for exports and for
further manufacturing
► There are penalties associated with non-payment/under-payment of MDET;
estimated biweekly tax payments are required to sum to 95% of quarterly
liability
► Both failure-to-pay and failure-to-file penalties apply
► The manufacturer or importer may try to recover the tax paid by:
► Increasing the price of the medical device
or
► Adding to the invoice price the amount of the tax as a separate charge
Page 18 Top-of-mind issues for tax-exempt providers
19. Provider implications — indirect tax liability
► Cost increases
► The vendor may increase the price or put additional charges on
the invoice, though they are not required to notify.
► For purchased convenience kits (aka custom packs), the tax will
apply to the value of the entire kit, even if there are otherwise non-
taxable items included.
Page 19 Top-of-mind issues for tax-exempt providers
20. Provider implications — direct tax liability
► Importing
► Direct sourcing
► Via group purchasing organizations (GPOs) or other similar arrangements
► Kits assembled for internal use are likely not taxable to
hospitals, though this is not confirmed until the IRS
finalizes regulations:
► Hospitals are generally exempt from registration and listing requirements of the
FDA when making kits for internal usage. The same taxable kit made by a
manufacturer (using the MDET definition of a manufacturer) that is sold on a
commercial basis may also be made by a hospital; however, because hospitals are
exempt from registration and listing requirements of medical devices, they may not
be creating taxable kits for purposes of the MDET.
► Some hospitals, however, may create medical devices and sell them to other,
unrelated, hospitals or others. It is less clear whether these sales should not result
in an excise tax, and this may be dependent on whether the FDA registration and
listing requirements apply (such are not addressed here).
Page 20 Top-of-mind issues for tax-exempt providers
21. Provider opportunities
► Contract review
► Understand where a vendor could change a behavior and cause a
hospital to have a direct liability
► Consider amending existing contracts to prevent the seller from
passing through the cost of this tax
► Kitting
► Restructure kits — focus on high value, high use
► Bring kitting in-house — consider cost/benefit analysis (assuming
the IRS concurs that hospitals will be exempt for internal-use
manufacturing)
► Implement exemption management process
► Leases
► Understand how tax applies to the manufacturer and ensure it is
not charged through on all lease payments
► Separate other economic transactions
Page 21 Top-of-mind issues for tax-exempt providers
22. Provider opportunities (cont.)
► Central procurement — trigger all direct liability in one
entity
► Centralize knowledge regarding what items are taxable:
► Understand which items are taxable devices and which are not to
ensure vendors are not arbitrarily trying to charge through, such as
an across-the-board price increase
► Be able to identify items that may at first appear to have a direct
liability because they are imported, but really may qualify for one of
the exemptions
Page 22 Top-of-mind issues for tax-exempt providers
24. ACT recommendations on Form 1023 —
updating for the future
► ACT report
► Project ASPIRE
► A — Alleviate backlog
► S — Streamline process
► P — Prioritize review
► I — Improve customer service
► R — Redirect resources
► E — Enhance quality control
Page 24 Top-of-mind issues for tax-exempt providers
25. ACT recommendations on Form 1023 —
updating for the future (cont.)
► Specific recommendations
► Develop fully interactive Form 1023
► Develop fully e-fileable Form 1023
► Facilitate Form 1023 database
► Primary objectives of Form 1023
► To be effective in identifying whether the organization qualifies
► To be consistent with structure and definitions of Form 990
► To be simplified by using a short-form and supplemental
schedules
► To be educational by organizing questions
Page 25 Top-of-mind issues for tax-exempt providers
26. ACT recommendations on Form 1023 —
updating for the future (cont.)
► IRS suggested next steps:
► Develop educational tools about substantive requirements
► Coordinate with the Treasury Department and Office of
Chief Counsel
► Examine recurring complaints and improve the filing process
► Expand the Review of Operations (ROO) program to follow up on
Section 501(c)(3) organizations whose exemption application
indicated potential future compliance issues
Page 26 Top-of-mind issues for tax-exempt providers
28. IRS Master File considerations
The Exempt Organization Business Master File (EO BMF) contains all of
the applicable information that the IRS has on file for exempt
organizations.
► A name/Employer Identification Number (EIN) mismatch can cause a
delay in payment from Centers for Medicare and Medicaid Services
(CMS) and other payors.
► May include the group and subordinate designation structure within the
IRS system as well
► An incorrect address of record (AoR) can invalidate a power of
attorney.
► An incorrect year-end can cause late filing notices (this happens often
with large systems where entities have different year-ends).
Page 28 Top-of-mind issues for tax-exempt providers
29. IRS Master File considerations (cont.)
► Incorrect public charity status on IRS BMF examples are as follows:
► A change in an organization’s public charity status is allowable on Form
990, Schedule A, but the IRS does not update its records from information
on the Form 990.
► Following the Pension Protection Act of 2006 (PPA), many organizations
updated their public charity status on Schedule A to avoid some of the
donor issues associated with the 509(a)(3) status, but did not request an
updated determination letter; therefore, the IRS still has the 509(a)(3)
status in the public record.
► There may be a public charity issue if the organization does not qualify for
the status claimed on Form 990.
► Form 8940 — an organization may submit, along with the applicable
user fee, a request for a letter confirming it qualifies for a new public
charity status.
Page 29 Top-of-mind issues for tax-exempt providers
30. BMF vs Select Check
There are two ways to check the deductibility of an organization with the
IRS:
► EO Business Master File
► A state-by-state downloadable spreadsheet including organizations’
names, address, private foundation status, year-end, group exemption
number, most recent 990 statistics and more.
► Select Check
► This option can check if an organization is eligible for tax-deductible
contributions, was automatically revoked or if it filed a 990-N.
► Entities exempt under a Group Exemption Number (GEN) are not
currently found with Select Check, but should be in the BMF. We have
also found instances where organizations were not found in the state
download, but were found in the applicable region download.
Page 30 Top-of-mind issues for tax-exempt providers
32. Five things you need to know
Who is affected?
The regulations affect all taxpayers with tangible property:
► Taxable subsidiaries
► Form 990-T activity
► Partnerships/joint ventures
Why is there so much interest in these regulations?
► The regulations depart from previous law and the
proposed regulations.
What do they cover?
► The regulations contain many broad-reaching rules — not just repairs.
When do they go into effect?
► The regulations apply to the 2014 tax year (were just extended
from 2012).
How are the regulations going to affect your company?
► The regulations present new implementation issues.
Page 32 Top-of-mind issues for tax-exempt providers
33. Key aspects
► What do the regulations cover?
1. Unit of property
2. Improvements
3. Materials and supplies
4. Acquisitions
5. Depreciation groupings and dispositions
► General changes for most taxpayers include:
► Method changes
► Compliance with Section 263A
► The regulations have broad applicability, with many
questions remaining.
► How to implement the regulations — do you have a plan?
Page 33 Top-of-mind issues for tax-exempt providers
34. What do they cover?
Acquisition of Improvements Depreciation
Materials and Leased tangible to tangible and
supplies property property property dispositions
► Definition ► Lessee/lessor ► Acquisition ► Unit of ► General asset
► Rotable spare expenditures costs property elections
parts ► Leasehold ► De minimis ► Betterments ► Multiple asset
► Election to improvements rule ► Restorations groupings
capitalize and ► Transaction ► New or ► Dispositions
apply de and different use
minimis rule investigatory ► Safe harbor
costs for routine
maintenance
Treas. Reg. Treas. Reg. Treas. Reg. Treas. Reg. Treas. Regs.
§ 1.162-3T § 1.167(a)-4T § 1.263(a)-2T § 1.263(a)-3T § 1.168(i)-1T and
§ 1.168(i)-8T
Other regulation sections amended for consistency.
Page 34 Top-of-mind issues for tax-exempt providers
35. Unit of property: buildings and building
systems
Heating, ventilation and air Fire protection and alarm system –
conditioning (HVAC) system – includes sprinklers, computer
includes motors, compressors, controls, fire doors/escapes, etc.
boilers, chillers, pipes, ducts, etc.
Security system – includes window
Plumbing system – includes pipes,
and door locks, security cameras,
drains, sinks, bathtubs, toilets, Building structure – all
security lighting, alarm system, etc.
water/sewer equipment, etc. other Section 1250
components, including
roof, walls, foundation,
Electrical system – includes wiring, finishes, windows,
outlets, junction boxes, lighting Elevator system – includes all
doors, etc. elevators in the building
fixtures, etc.
Gas distribution system – includes Escalator system – includes all
pipes and equipment used to escalators in the building
distribute gas, etc.
Page 35 Top-of-mind issues for tax-exempt providers
36. Materials and supplies
► Definition: tangible property (not inventory) that is:
► A component acquired to maintain, repair or improve a unit of tangible property
or
► Fuel, lubricants, water and similar items that are reasonably expected to be
consumed in 12 months or less
or
► A unit of property with an economic useful life of 12 months or less
or
► A unit of property costing US$100 or less
or
► Identified as such in guidance
► The new definition may mean that some assets are depreciable property
rather than materials and supplies.
Page 36 Top-of-mind issues for tax-exempt providers
37. Tangible property
De minimis rule — book conformity election
► De minimis rule to conform to book expense
► Must have applicable financial statements (AFS)
► Must expense amounts in its AFS consistent with written
capitalization procedures
► By taxable entity, aggregate amount less than ceiling of:
► 0.1% of the taxpayer’s tax gross receipts
or
► 2.0% of the taxpayer’s total book depreciation and amortization
► If an entity exceeds the ceiling, excess amount must be capitalized
► May choose which items to capitalize
► Exclusions
► Land
► Inventory
Page 37 Top-of-mind issues for tax-exempt providers
38. The procedural guidance
► Roadmap for implementing the regulations, including:
► Two-year waiver of the scope limitations: provides taxpayers under
examination the ability to file method changes outside of window periods
without obtaining examination consent and waives the five-year limitation
► Specific guidance related to the applicability of statistical sampling for
computing Section 481(a) adjustments and tax-return positions
► Provisions indicating which method changes will have a full 481(a) adjustment
versus those made on a modified cut-off (based on the effective date of the
regulations)
► 19 new automatic changes
► Many of the new changes can be filed on a single Form 3115, although
multiple 3115s are likely
► Compliance with § 263A is generally required
► Self–constructed assets and inventory
► File in Ogden, UT, office in lieu of IRS National Office
Page 38 Top-of-mind issues for tax-exempt providers
39. Notice 2012-73
Notice 2012-73 (issued 12/20/2012) announced:
► Temporary regulations (currently effective for tax years beginning on
or after 1/1/2012):
► Will be modified to be effective for tax years beginning on or after
1/1/2014
► May be optionally applied for tax years beginning on or after 1/1/2012
► Optional early application may be done piecemeal
► Final regulations:
► Are anticipated to be published in 2013
► Will be effective for tax years beginning on or after 1/1/2014
► May be optionally applied for tax years beginning on or after 1/1/2012
► Will include modifications to de minimis rule, dispositions rules, and the
routine maintenance safe harbor
Page 39 Top-of-mind issues for tax-exempt providers
40. Thank you
for your participation and feedback!
Page 40 Top-of-mind issues for tax-exempt providers