Herschman Gary W
Health and Hospital Law Practice Group, Sills Cummis Epstein & Gross, PC, Newark, NJ, USA.
Healthc Financ Manage. 2004 Oct;58(10):72-4, 76.
In St. David's vs. IRS, a not-for-profit health system effectively challenged the IRS's determination that the system should be disqualified from tax exemption because it had entered a 50/50 joint venture with a for-profit system. The court decisions in St. David's, coupled with a recent IRS ruling, Revenue Ruling 2004-51, provide insight into how a not-for-profit hospital can structure such a joint venture to avoid jeopardizing its tax-exempt status.
