Tax News & Views: Health Care Edition

April 2017 | Vol. 12 No. 34

Tax News & Views: Health Care Edition is a timely news summary bulletin authored by the Health Care Industry Group, Deloitte Tax LLP. The newsletter contains highlights from the latest tax developments in health care on Capitol Hill, at the White House, at the Internal Revenue Service, at the Treasury Department and in the courts. It is a valuable resource for tax and other professionals involved in the tax-exempt health care providers and health plans sectors, helping them remain current on tax developments that stand to have an impact on their businesses.

Rev. Proc. 2016-47 revises hardship exception to 60-day rule

Internal Revenue Code (IRC) Sections 402(c)(3) and 408(d)(3) provide that distributions from a qualified retirement plan or IRA are not included in income if they are transferred to a qualified retirement account within 60 days. IRC Sections 402(c)(3)(B) and 408(d)(3)(i) provides that the Secretary may waive the 60-day rollover requirement and Rev. Proc. 2003-16 provides the procedure for a taxpayer to apply to the IRS to receiver a waiver of this requirement.

Rev. Proc. 2016-47 allows taxpayers to self-certify to plan administrators or IRA trustees that the 60 day roll over window was missed for cause and the early distribution taxes should not apply if one of eleven enumerated reasons apply. The Rev. Proc. provides a safe harbor if the rollover contribution to a new qualified retirement account is made within 30 days after the reason or reasons no longer prevent the taxpayer from making the contribution. A sample self-certification letter is available as an appendix to the Rev. Proc.

Rev. Proc 2016-47 became effective August 24, 2016.

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Approved 1023-EZ data available on-line
On February 22, 2017, the IRS announced that all publicly available data from approved Forms 1023-EZ is now available electronically online. Information is currently available for applications approved during 2014, 2015, and 2016. Information will be updated quarterly beginning with the first quarter of 2017.

Deadline approaching for supported organization notifications
The notification requirement deadline for IRC Section 509(a)(3), Type III functionally and non-functionally integrated supporting organizations with a December 31, 2016 year-end is May 30, 2017. For additional information on this requirement, please reach out to your Deloitte contacts.

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Additional Resources

Deloitte Center for Health Solutions

The source for health care insights: The Deloitte Center for Health Solutions (DCHS) is the research division of Deloitte’s Life Sciences and Health Care practice. The goal of DCHS is to inform stakeholders across the health care system about emerging trends, challenges, and opportunities.

Health Care Current

Weekly insights to keep you informed and ahead. This weekly series explores breaking news and developments in the US health care industry, examines key issues facing life sciences and health care companies and provides updates and insights on policy, regulatory, and legislative changes.

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