Tax News & Views: Health Care Edition

Revenue Procedure 2022-20

Rev. Proc. 2022-20 provides guidance regarding the public approval requirement under § 147(f) of the Internal Revenue Code for tax-exempt qualified private activity bonds, allowing that hearings held by teleconference as described in the revenue procedure will be treated as held in a location that, based on the facts and circumstances, is convenient for residents of the approving governmental unit for the purpose of § 1.147(f)-1(d)(2) of the Income Tax Regulations.

Additional Notices Temporarily Suspended

To help avoid confusion when a filing is still in process, the Internal Revenue Service (IRS) announced in an Exempt Organizations Update newsletter dated March 25, 2022 it temporarily suspended the issuance of several notices generally mailed to tax-exempt or governmental entities in case of a delinquent return. The suspended notices are:

• CP214, Reminder Notice About Your Form 5500-EZ or 5500-SF Filing Requirement;
• CP217, Form 940 Not Required — Federal, State, and Local Government Agencies;
• CP259A, First Taxpayer Delinquency Investigation Notice – Form 990/990EZ/990N;
• CP259B, First Taxpayer Delinquency Investigation Notice – Form 990PF;
• CP259D, First Taxpayer Delinquency Investigation Notice – Form 990T;
• CP259F, First Taxpayer Delinquency Investigation Notice – Form 5227;
• CP259G, First Taxpayer Delinquency Investigation Notice – Form 1120-POL;
• CP259H, First Taxpayer Delinquency Investigation Notice – Form 990/990EZ;
• CP403, First Delinquency Notice — Form 5500 or 5500-SF; and
• CP406, Second Delinquency Notice – Form 5500
  

Reporting compensation paid to management companies on Form 990 series annual returns

IRS Announcement 2021-18 revokes Announcement 2001-33 that provided tax-exempt organizations with reasonable cause for purposes of relief from the penalty imposed under § 6652(c)(1)(A)(ii) of the Internal Revenue Code if they reported compensation on their annual information returns in the manner described in Announcement 2001-33 instead of in accordance with Form 990 series instructions. Announcement 2001-33 allowed tax-exempt organizations that pay a management company directly for services provided by an officer, director, trustee, or key employee to report the amount paid directly to the management company on their annual tax return instead of reporting the compensation paid to each officer, director, trustee, or key employee who performed the services for the tax-exempt organization. The new Announcement 2021-18 instructs affected tax-exempt organizations to follow the specific instructions to the Form 990, Form 990-EZ, and Form 990-PF, effective for annual information returns required for taxable years beginning on or after January 1, 2022. Announcement 2021-18 asserts that having all tax-exempt organizations report compensation in accordance with the specific Form 990 series instructions will improve transparency and compliance by making it easier for the public and the IRS to understand financial operations, including compensation arrangements.

Did you know?

Form 1096 Instructions Updated
The Box 5 instructions of 2022 instructions for Form 1096, Annual Summary and Transmittal of U.S. Information Returns, have been revised to correct the applicable box references for Forms 1099-DIV and 1099-MISC. The IRS noted that changes are reflected in downloads on or after April 4, 2022.

Environmental, social, and governmental (ESG) resources
Deloitte Insights provides resources on managing climate change, meeting stakeholder expectations, and evolving your organization to meet the challenges ahead.

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 Forward blog
Connect to the forces of change across life sciences and health care today. Explore our latest leadership insights to stay ahead of industry trends and key issues on health care, medtech, and biopharma.

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