The coming changes in tax-exempt health care finance

On December 30, 1994, the Internal Revenue Service (IRS) published proposed regulations (Proposed Regulations) that if enacted would significantly change the climate and rules of federal income tax law controlling the issuance and maintenance of tax-exempt bonds for governmental and 501(c)(3) health care borrowers. This article (1) summarizes the aspects of the Proposed Regulations dealing with private activity tests, management contracts, allocation and accounting rules, change in use of financed facilities, and antiabuse rules, and (2) summarizes the possible interrelationship of the IRS's audit program for tax-exempt bonds and the Proposed Regulations. The article reviews features of the Proposed Regulations that will affect either the costs or administrative burdens of managing the federal tax compliance of future tax-exempt health care borrowings.