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Section 501(c)(3) Healthcare Bonds General Rules for Qualified IRC
- 100% of the project financed must be owned by IRC Section 501(c)(3) organization.
- No more than 5% of the net proceeds may be used in private trade or business.
- Must have a TEFRA hearing.
- No prohibited facilities (skybox, retail liquor, gambling, etc.).
- Weighted average maturity of Bonds may not exceed 120% of useful life of assets financed (ignore land; life of working capital equals zero).
- No more than 2% of tax-exempt proceeds may pay costs of issuance.
- Arbitrage and rebate rules apply.
Management Contract Rules under Revenue Procedure 97-13
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For-profit manager can be paid expenses and reasonable fee for services.
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No part of manager’s fee may be based on net revenues.
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Formulaic approach to permitted duration—15 years if 95% of fee is fixed; 10 years if 80% of fee is fixed; 5 years if 50% of fee is fixed. With 50% fixed fee, contract must be terminable by the 501(c)(3) at year 3 without penalty.
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(St. Joes Hospital, Phoenix, Arizona)
Benefits of Qualified IRC Section 501(c)(3) Bonds
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No Private Activity Bond cap allocation required.
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No prohibition on advance refundings.
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No limit on land purchase. No “substantial user/related party” problem.
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No restriction on acquisition of used property (existing assets).
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No Alternative Minimum Tax (“AMT”). |