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Nonprofit Joint Ventures and Community Benefit: A New Approach

Nonprofit Joint Ventures and Community Benefit: A New Approach

As nonprofit hospitals face declining reimbursements from insurers and government payers, many nonprofit hospitals look to partnerships with for-profit entities. New requirements for nonprofit hospitals in the Affordable Care Act of 2010 should provide guidance for maintaining tax-exempt status.
An Imprudent Proposal: The Case Against Restricting the Comparable Uncontrolled Transaction Method for U.S. Transfer Pricing

An Imprudent Proposal: The Case Against Restricting the Comparable Uncontrolled Transaction Method for U.S. Transfer Pricing

In December 2009, the Internal Revenue Service found itself on the losing end of a high-profile case regarding a taxpayer’s use of the comparable uncontrolled transaction (CUT) method to evaluate cost-sharing arrangements. After looking at buy-in payments persuant to a cost-sharing arrangement, the U.S. Tax Court found that the CUT method was the best method to price the transaction.