Tax News & Views: Health Care Edition


Tax News & Views: Health Care Edition

May 2021 | Vol. 12 No. 80

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.

TE/GE Compliance Program and Priorities

The Internal Revenue Service’s Tax Exempt and Government Entities (“TE/GE”) Division released its fiscal year 2021 Compliance Initiatives. These initiatives align with the Fiscal Year 2021 Program Letter and Strategic goals that have been previously released by the IRS. The list below contains a summary of some the strategies outlined in the release.

  • Worker Classification: Review of worker classification of treatment of independent contractors instead of employees.
  • Officers treating exempt organization as Schedule C business: Determine if officers and other insiders of exempt organizations are claiming expenses of exempt organizations as business deductions that are taken on Schedule C of the Form 1040, US Individual Income Tax Return.
  • Form 990-N Filers/Gross Receipts Model: Determine if exempt organization were eligible to file a Form 990-N, Annual Electronic Filing Requirement for Small Exempt Organizations, where related filings indicate that the $50,000 gross receipts threshold was not met.
  • Excise Tax on Excess Compensation: Review of the impact of the IRC 4960 excise tax on excess compensation. Based on a review of IRS data, there is a high volume of exempt organizations that paid compensation over $1 million to at least one “covered employee” but did not file and report on the Form 4720, Return of Certain Excise Taxes Under Chapter 41 and 42 of the Internal Revenue Code.
  • Misfiling of Form 990-N by IRC Section 509(a)(3) organizations: Review IRC section 509(a)(3) organizations that file the Form 990-N to determine if the organizations meet the eligibility standards to file the form.
Tax News & Views: Health Care Edition May 2021

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Monitor Institute
The Monitor Institute by Deloitte is a team within Deloitte LLP that works with social impact-focused organizations and their leaders, helping to make hard choices and take the necessary actions to advance progress on pressing societal change. The Monitor Institute by Deloitte has published thought leadership in the areas of social impact and philanthropy. The Monitor Institute has a series of articles and also maintains a blog on latest trends.

Public Comments Request for IRS 2021-2022 Priority Guidance Plan
The Internal Revenue Service released Notice 2021-28, which it requests comments on the 2021-2022 Priority Guidance plan. This plan will identify guidance projects that the Department of Treasury and Internal Revenue Service will actively work on as priorities from July 1, 2021 to June 30, 2022. Submissions of any comments for consideration for the 2021-2022 priority guidance plan are request by Friday, May 28, 2021 and can be made online via the Federal eRulemaking Portal at (using IRS-2021-0004 in the search) or by mail to the following address:

Internal Revenue Service
Attn: CC:PA:LPD:PR (Notice 2021-28) Room 5203
P.O. Box 7604
Ben Franklin Station
Washington, D.C. 20044

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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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