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Document(s) published by this organization: 3

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HTMLInternal Revenue Service finds Contracts protecting against Foreign Currency Fluctuations not to be Insurance
Christopher M. Flanagan, Rebecca Melaas;
Legal Alert/Article
March 25, 2015, previously published on March 23, 2015
Companies looking to establish insurance coverage, especially in situations involving a captive type of arrangement, will, as always, need to focus on the qualification of the coverage as insurance for U.S. federal income tax purposes. While this traditionally involves an analysis of the risk...


HTMLCMS Announces New Next Generation ACO Model
Michaela ("Kayla") Tabela;
Legal Alert/Article
March 25, 2015, previously published on March 20, 2015
On March 10, 2015, the Centers for Medicare & Medicaid Services (“CMS”) announced a new Next Generation ACO Model for Medicare accountable care organizations or “ACOs.” This proposal further expands the shared risk models already established under the Medicare Shared...


HTMLIRS Provides Interim Guidance as to Private Business Use and Accountable Care Organizations and Expands Safe-Harbors for Qualified Management Contracts
Joe E. Forrester, Christie Lombard Martin, Antonio D. Martini;
Legal Alert/Article
February 17, 2015, previously published on November 2014
On October 24, 2014, the IRS published Notice 2014-67 (the “Notice”) which provides interim guidance for determining whether a State or local government entity or 501(c)(3) organization that benefits from tax-exempt bond financing will be considered to have private business use of its...