Healthcare Entities and LLCs: Leveraging IRS Guidance on Requirements for LLCs to Qualify as Tax-Exempt Entities

Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
- work Practice Area
Health
- event Date
Wednesday, March 23, 2022
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
-
This 90-minute webinar is eligible in most states for 1.5 CLE credits.
This CLE webinar will guide healthcare counsel on the IRS Notice 2021-56. The panel will discuss the implications of the notice for healthcare organizations. The panel will address leveraging LLCs with Section 501(c)(3) tax-exempt organizations. The panel will offer best practices for establishing and maintaining tax-exempt status for healthcare organizations.
Faculty

Mr. Mancino has extensive experience in audits, appeals, and other tax controversies, including tax litigation. He has served as counsel to health care clients in a case that defined the limits of tax-exempt organizations participating in health care joint ventures and represents tax-exempt health plans throughout the United States. Mr. Mancino has authored or co-authored five books and treatises and more than 90 articles concerning tax-exempt organizations and health care issues. He is a former president of the American Health Lawyers Association and served for three years as vice chair publications of the ABA’s Tax Section. He is a frequent lecturer/speaker on many legal, tax and health care subjects. He enjoys a national reputation as one of the country’s top health care and tax-exempt organization lawyers.

Mr. Lezotte has substantial experience in corporate, healthcare, exempt organization, and tax matters, including corporate and nonprofit governance, hospital-physician ventures and other healthcare transactions, regulatory investigations, tax exemption matters, and a wide range of business and commercial transactions. He is former general counsel of Oakwood Healthcare Inc. (now a part of Beaumont Health), where he was responsible for all of the system's legal services, supervision of in-house legal staff, supporting strategic initiatives and joint ventures, and the engagement and oversight of outside counsel on a wide variety of legal matters. Mr. Lezotte also served as outside general counsel for another Michigan health system, working with the system’s board and executive management on strategic matters, joint ventures, and contracting matters, and supervising legal and compliance activities. He has conducted presentations on a number of topics involving health law, nonprofit organizations, and tax matters.
Description
In late 2021, the Internal Revenue Service released a notice that sets forth additional requirements a limited liability company must meet to obtain a determination letter recognizing its tax-exempt status. The announcement renews interest in using LLCs by organizations, including charitable health systems and related healthcare entities, for tax-exempt purposes.
The IRS notice represents the first formal guidance for LLCs seeking federal tax exemption. The notice lays out what an LLC must include in its articles of organization and operating agreement to meet the requirements for tax-exempt status. An LLC with tax-exempt status would allow for more structural flexibility for healthcare entities. Following this guidance, LLCs are a strategic option that tax-exempt healthcare entities should consider.
Listen as our authoritative panel examines the recent IRS guidance and the implications for healthcare organizations. The panel will address leveraging LLCs with Section 501(c)(3) tax-exempt organizations. The panel will offer best practices for establishing and maintaining tax-exempt status for healthcare organizations.
Outline
- IRS Notice 2021-56
- Implications for healthcare organizations
- Best practices for healthcare organizations to leverage the new IRS guidance
Benefits
The panel will review these and other high priority issues:
- What guidance does the new IRS notice provide for using LLCs in connection with Section 501(c)(3) tax-exempt organizations?
- What steps should counsel take to leverage the new IRS guidance?
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