Tax Reform Act of 1986: implications and trends

The Tax Reform Act of 1986 contains several changes that substantially reduce economic flexibility for not-for-profit hospitals and healthcare systems. These changes, involving limited partnerships, investment tax credit, depreciation, and income deferral plans, among other items, carry several implications. Tax-motivated joint ventures will no longer be attractive to physician investors, donations to hospitals are expected to decline by up to 15 percent, and flexibility in attracting and retaining high-caliber employees is reduced. Efforts to reduce the federal budget deficit and renewed scrutiny of unrelated business income further jeopardize economic flexibility. Another threat is intensified Internal Revenue Service scrutiny of Form 990, which is filed by all not-for-profit organizations with $25,000 or more in annual gross receipts, and Form 990T, which is used to report unrelated business income. Measures to protect facilities' economic flexibility include careful return preparation, alternative recruitment tactics, objective opinions, refusal of high-risk deals, and outside appraisals.