Some tax-exempt bond issues could become taxable.

The IRS recently launched a new program to audit healthcare mergers-and-acquisition financing arrangements. To date, the IRS has focused on transactions involving IDSs in which tax-exempt bonds issued on behalf of the participants have been used to prepay the outstanding debt of one or both participants. The IRS is concerned that such tax-exempt financing may involve impermissible advance-refunding of the previous debt, in which case the financing would be deemed taxable and the participants subject to penalties.