The Internal Revenue Service today issued Notice 2014-67, a copy of which is linked below.  This Notice provides long-awaited guidance on the extent to which private business use of a tax-exempt bond-financed facility results from participation in an accountable care organization.  This Notice also amplifies existing guidance under Revenue Procedure 97-13 regarding the types of management contracts that do not give rise to private business use of a tax-exempt bond-financed facility.  After we’ve carefully reviewed and reflected on the Notice, we will post a more detailed analysis of it.

IRS Notice 2014-67