Workshop D Unique Tax Issues in the Healthcare and Non-Profit - - PDF document

Tuesday & Wednesday, January 28‐29, 2020

Hya Regency Columbus, Columbus, Ohio

Workshop D

Unique Tax Issues in the Healthcare and Non-Profit Entities

Tuesday, January 28, 2020 1:45 p.m. to 2:45 p.m.

Biographical Information Jeffrey L. Stansberry, CPA, MT - Tax Manager, OhioHealth 80 E. Broad St, Columbus, OH 43215 jeffrey.stansberry@ohiohealth.com (614) 544-4336 Fax (614) 544-4470 Jeff started his career in public accounting and was at GBQ Partners for over four years. He then transitioned into industry and was at BISYS/Citi for over six years. After being in public and industry for nearly two decades, he decided to shift his focus into the tax-exempt sector. For over three years, Jeff has led up the tax department at OhioHealth, central Ohio’s largest healthcare

• system. Jeff is responsible for leading OhioHealth’s annual federal, state, and local tax

compliance process while providing oversight and communication to the entire system of over 20,000 employees. Jeff is a graduate of The Ohio State University with a BS in Business Administration (Honor Classes) and received a Master’s in Taxation from Capital University Law School. Christopher J. Swift, Partner, Baker Hostetler LLP 1900 East 9th Street, Suite 3200, Cleveland, OH 44114-3482 cswift@bakerlaw.com 216.861.7461 Chris Swift is a healthcare and tax lawyer who counsels the healthcare industry and other businesses by guiding them through governmental, tax and regulatory issues. He keeps non-profit organizations tax-exempt, assists all taxpayers in reducing state and local taxes and finds tax and regulatory incentives to grow companies. He currently serves both as a National Co-Leader of the firm’s Healthcare Industry Team and as Coordinator of the Cleveland office’s Tax, Personal Planning and Employee Benefits Group. He served as a member of the firm’s Policy Committee, 2004 through 2009. Chris has lectured on state and local taxes to several organizations, including the Cleveland Metropolitan Bar Association, the Columbus Bar Association and the Committee on State Taxation. In 1988, he was the Chair of the Cleveland Bar Association’s State and Local Tax Institute. In 1990-91, he served as Chair of the Cleveland Bar Association’s General Tax Committee. Chris has also served as Chair of the 2008 Cleveland Tax Institute and the CMBA’s 1998 Health Law Institute. Chris is a member of the American, Ohio and Cleveland Metropolitan Bar Associations, as well as the American Health Lawyers Association. Since 1997, Chris has been listed annually in the Best Lawyers in America. He was named by Best Lawyers as “2010 Cleveland Tax Lawyer of the Year” and “2011 Cleveland Health Care Lawyer of the Year.” Both honors are bestowed upon only one lawyer per specialty in each community. Chris has been named an “Ohio Super Lawyer” for the past ten years. Stephen M. Palmer, CPA, Senior Manager, SALT Plante Moran, 250 S. High St., Ste. 100, Columbus, OH 43215 614-222-9137 Fax: 248.327.8537 Stephen.Palmer@plantemoran.com Stephen spent more than 6 years at the Ohio Department of Taxation primarily involved in auditing various Ohio taxes. The Ohio tax auditing experience crossed multiple industries and included pass- through entity tax, sales and use tax, the former Ohio franchise and personal property taxes, income tax, and withholding tax. For more than ten years, Stephen has provided value added service to clients in the private sector. His experience includes multi-state taxation in the manufacturing, distribution, healthcare, and service industries. Value-added services include audit resolution, nexus reviews, sales and use tax studies, voluntary disclosure representation, tax planning, and tax structuring, and due diligence. Additionally, Stephen frequently writes state and local tax alerts and presents at various tax conferences. Stephen is a graduate of Cedarville University, is a member of the Ohio Society of CPAs, and is a member of the tax committees for the Ohio Chamber of Commerce, the Ohio Manufacturer’s Association, and the Ohio Society of CPAs.

Healthcare Industry & Nonprofit Entities Unique Tax Issues

Jeffrey Stansberry ‐ OhioHealth Christopher Swift ‐ Baker Hostetler Stephen Palmer ‐ Plante Moran

Agenda

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TAX REFORM SALES AND USE TAX COMMERCIAL ACTIVITY TAX PROPERTY TAX EXEMPTIONS IMPORTANT RISK CONSIDERATIONS

Basis for Federal Income Tax Exemption

• Section 501(c)(3) requires that the corporation be “organized and
• perated exclusively for religious, charitable, scientific . . . Or

educational purposes” and that “no part of the net earnings of which inures to the benefit of any private shareholder or individual.”

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Choice of Entity

• Chapter 1702 of the Ohio Revised Code (Ohio Nonprofit Corporation Law)
• Some nonprofits are unincorporated associations, trusts, limited liability

companies, partnerships, or disregarded entities

• Section 501 of the Internal Revenue Code

‒ While many nonprofits are tax‐exempt for federal income tax purposes under Section 501(c)(3), there are many subsections like Section 501(c)(4) ‒ Some nonprofits are taxable ‒ Some for‐profit corporations are tax‐exempt

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Choice of Entity

• Different Rules for Different Taxes

‒ Federal Income Tax ‒ FUTA/SUTA

• Reimbursing Employer Status

‒ Ohio Sales & Use Tax ‒ Ohio Real Property Tax ‒ Ohio Commercial Activity Tax

5

Tax Reform – Excise Tax on Compensation

• Section 4960 imposes a 21 percent excise tax on the compensation of

certain highly compensated employees of tax‐exempt organizations (effective 1/1/2018)

• IRS issued Notice 2019‐09 – Interim Guidance under Section 4960 of the
• IRC. It is almost 100 pages long and includes close to 40 Q&As
• Defined terms

‒ Applicable tax‐exempt organizations ‒ Covered Employees ‒ Excess Compensation ‒ Excess Parachute payment

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Tax Reform – Excise Tax on Compensation > $1M (Form 4720)

• For each legal entity, the five highest compensated “common law” employees for

the tax year, or any prior year

• Deferred comp considered once it vests
• Does not include remuneration paid to licensed medical professionals for

performance of medical services

• The excise tax is paid by the organization
• Tax years beginning 1/1/18 or later (FY19 comp for FY filers)
• Calendar filers ‐ initial due date 5/15/19 with payment with a 6 month extension
• Fiscal year end filers ‐ initial due date 4 ½ months (or 15th day of 5th month) after

fiscal year end with payment with a 6 month extension

• Guidance available through draft 4720 and instructions
• Further regulatory guidance expected
• No estimated tax payments and overpayments are automatically refunded by IRS

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Tax Reform – Excise Tax on Compensation > $1M (Form 4720)

• Wages as defined under Section 3401(a) ‐ W‐2, BOX 1
• Plus: Annual earnings on vested portion of SERP balance
• Plus: Section 457(b) Contributions
• Plus: Earnings on Section 457(b) accounts
• Plus: Any imputed interest not already included in W‐2, Box 1 (i.e. split‐

dollar life insurance)

• Plus: Other amounts vested during the period
• Less: Roth contributions included in the W‐2, Box 1 above
• Less: Group term‐life insurance included in the W‐2, Box 1 above

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Tax Reform – Segmentation of UBI by Trade or Business Activity (Form 990‐T)

• Organizations with one or more trade or business (T/B) subject to UBIT

must calculate the tax separately for each T/B

• Tax years beginning 1/1/18 and later
• Calendar filers ‐ initial due date 5/15/19 with payment (with a 6 month

extension)

• Fiscal year end filers ‐ initial due date 4 ½ months (or 15th day of 5th

month) after fiscal year end with payment (with a 6 month extension)

• Notice 2018‐67 provides interim guidance with further guidance

expected.

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Tax Reform – UBIT taxation of fringe benefits

• Early Christmas present – the so‐called “Parking Tax” was repealed as of

December 20, 2019 and made retroactive to the enactment of the tax.

• As a reminder, this was a tax applied to certain qualifying expenses of

nonprofit entities.

• Recommendation is to hold off on taking any action on claiming refunds

(i.e. filing amended returns to claim a refund of the tax) to see if the IRS will issue a streamlined procedure for requesting refunds.

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Tax Reform – Private Foundation Excise Tax

• Simplification of excise tax rate to 1.39%
• Effective for tax years beginning after the December 20, 2019
• Eliminates potential penalty for certain charitable giving and

alleviates the need to track, monitor, and maintain charitable distributions for that purpose

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Impact of External Change

• Federal and State Health Care Policy

‒ EMTALA and other Safety Net Acts applicable to for‐profit providers ‒ Affordable Care Act ‒ Expansion of Medicaid ‒ Schedule H of Form 990

• Correlation of Value of Tax Benefits to Level of Charitable Care

‒ Percentage of Charitable Care is decreasing

• How Much is Enough?

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Ohio Nonprofit Corporation Definition

• Ohio Rev. Code 1702.01(C) defines “Nonprofit Corporation” as a

“corporation that is formed otherwise than for the pecuniary gain

• r profit of, and whose net earnings or any part of them is not

distributable to, its members . . . .”

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Ohio Public Benefit Corporation Definition

• “Public benefit corporation” is defined as a “corporation that is

recognized as exempt from federal income taxation under section 501(c)(3) . . . . Or is organized for a public or charitable purpose . . . .” Ohio Rev. Code (“ORC”) 1702.01(P).

• Sometimes the ORC piggybacks on Section 501(c)(3), but not always.

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Basis for Ohio Sales Tax Exemption

• Purchases by organizations exempt from taxation under Section

501(c)(3) are generally exempt from Ohio sales and use tax. Ohio

• rev. Code 5739.02(B)(9) and 5741.02(C)(2).

‒ Some states like Florida and Kentucky require tax‐exempt hospitals to include current federal determination letter in application.

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Sales and Use Taxes for Nonprofit Companies

• Sales tax exemption is for purchases not sales*

‒ *Safe harbor – ORC 5739.02(B)(9) ‒ Cafeteria and other food sales

• What is food?
• How is “premise” applied?

‒ Online sales or non‐core revenue streams ‒ Who is the consumer? ORC 5739.01(D)

• Use tax filings for related for‐profit entities

‒ Proper use of exemption certificates ‒ Communication with vendors ‒ Intercompany transactions

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Sales Tax Safe Harbor

• Certain sales by Section 501(c)(3) Entities

‒ Sales of services or tangible personal property, other than motor vehicles, mobile homes, and manufactured homes, by organizations exempt from taxation under section 501(c)(3) of the Internal Revenue Code of 1986, or nonprofit organizations operated exclusively for charitable purposes, provided that the number of days

• n which such tangible personal property or services, other than

items never subject to the tax, are sold does not exceed six in any calendar year. If the number of days on which such sales are made exceeds six in any calendar year, the organizations shall be considered to be engaged in business and all subsequent sales by it shall be subject to the tax.

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Healthcare Sales Tax Exemption

• Purchases by Section 501(c)(3) Entities

‒ Sales of tangible personal property or services to organizations exempt from taxation under section 501(c)(3) of the Internal Revenue code of 1986, and to any other nonprofit organizations

• perated exclusively for charitable purposes in this state, no part of

the net income of which inures to the benefit of any private shareholder or individual, and no substantial part of the activities of which consists of carrying on propaganda or otherwise attempting to influence legislation; sales to offices administering one or more homes for the aged or one or more hospital facilities exempt under section 140.08 of the Revised Code; and sales to organizations described in division (D) of section 5709.12 of the Revised Code.

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Healthcare Sales Tax Exemption (cont.)

• Definition of “Charitable Purposes” for Ohio Sales & Use Tax

‒ “Charitable purposes” includes the relief of poverty; the improvement of health through the alleviation of illness, disease, or injury; the operation of an organization exclusively for the provision

• f professional, laundry, printing, and purchasing services to

hospitals or charitable institutions and the operation of a home for the aged, as defined in section 5701.13 of the Revised Code.

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Sales and Use Taxes for Nonprofit and Healthcare Companies

• Independent Living, Assisted Living, Long‐term Care

‒ Revenue stream evaluation ‒ Potential areas for consideration

• Cafeterias, dining rooms, and other food service
• Movie theatres
• Gift shops
• Beauty salons
• Fitness centers
• Building and construction / business fixture

‒ Admissions tax

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Sales and Use Taxes for Nonprofit and Healthcare Companies

• Purchases of building and construction materials and services sold to

construction contractors for incorporation into a building under a construction contract with a section 501(c)(3) entity when the building is used exclusively for exempt purposes.

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Home Health Care Considerations

• Municipal Employer Withholding

‒ Municipal income tax 20 day occasional entrant rule ‒ Courtesy withholding ‒ Common paymasters ‒ Payroll amounts reported on city withholding versus payroll factor on city income tax returns

• Municipal Net Profits Tax

‒ Sales factor – source services to where performed ‒ Payroll factor – see above ‒ Alternate apportionment requests ‒ Centralized filing can create significant savings

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Basis for Ohio Commercial Activity Tax Exemption

• Defined by rule to be very broad.
• Two criteria

‒ Organized other than for pecuniary gain or profit ‒ Operates consistent with its organization

• Includes entities organized under ORC 1702, 1707, 1711, 1713, 1715,

1716, 1717, 1719, 1721, 1724, 1725, 1727, or 1733

• Includes organizations formed for funding political campaigns
• Charitable lead trust is a nonprofit during the lifetime of the grantor. The

trust loses its nonprofit status when the grantor passes away

• If all owners are nonprofit organizations, distributions to these owners

does not deprive the nonprofit status

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Commercial Activity Tax for Nonprofit Companies

• Exemption for nonprofits
• Disregarded entity is not disregarded for CAT purposes
• Consolidated or combined filings
• Nonprofit entity can be common parent

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Historical Background on Property Tax Exemption

• Prior to New Deal, local government or charitable organizations

were responsible for alleviation of poverty and providing health care for the poor. ‒ Local governments owned and operated hospitals, requiring public expenditures

• Exemptions trace back to English Statute of Charitable Uses of

1601.

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Basis for Ohio Real Estate Tax Exemption

• “Real and tangible personal property belonging to institutions that

is used exclusively for charitable purposes shall be exempt from taxation . . . .” Ohio Rev. Code 5709.12(B).

• Like most states, Ohio requires both charitable ownership and

charitable use for ad valorem exemption.

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Implications for Ohio Hospitals

• Real property tax exemption in Ohio for hospitals is generally governed by two

sections [Revised Code §5709.12(B) and §5709.121] employing the general law

• f charity for organizations that use property for charitable purposes.

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Implications for Ohio Hospitals

• Applying these laws specifically to hospitals and other healthcare organizations, the Ohio Supreme

Court has consistently found through various decisions that the property of charitable hospitals is exempt, even if the hospital charges for its services: ‒ “This Court has embraced an expansive view of charity that involves the provision of public benefit without regard to the ability to pay.” [Planned Parenthood Assoc. v. Tax Comm’r, 5 Ohio St.2d 117 (1966)] ‒ “The provision of medical or ancillary healthcare services qualifies as charitable if those services are provided on a nonprofit basis to those in need, without regard to race, creed, or ability to

• pay. An organization promoting community health will be acting charitably if it provides services

without regard to race, color, creed or ability to pay. It is the use of the property rather than the fact that revenues are collected and received from property which is controlling.” [Church of God in N. Ohio v. Levin, 124 Ohio St.3d 36 (2009)] ‒ “The generation of profit by the property ‘does not remove it from the statutory category of exempt property,’ because ‘the evidence shows that the parking lot is an essential and integral part of the hospital’s function and not property used mainly for income purposes.’” [Girl Scouts‐Great Trail Council v. Levin, 113 Ohio St.3d 24 (2007), citing Bowers v. Akron City Hosp., 16 Ohio St.2d 94 (1968)]

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Implications for Ohio Hospitals

• The Ohio Department of Taxation has not been using the Provena case to

attack exemption of Chapter 140‐bond financed properties under Ohio Revised Code §140.08(A).

• Therefore, the most certain way to avoid problems with Provena for

OhioHealth is to use the exemption for hospital facilities financed with Chapter 140 bonds whenever possible.

• In that regard, Ohio Revised Code §140.08(A) exempts hospital facilities

from all taxes, including real property taxes if: ‒ (i) the facilities are "hospital facilities” (a very broadly defined term), ‒ (ii) the facilities are financed in whole or in part with "obligations" issued by a "public hospital agency," and ‒ (iii) the facilities are actually used as hospital facilities.

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Ohio Hospital Facility Exemption

• O.R.C. 140.08 provides that “hospital facilities” that are “purchased,

acquired, constructed, or owned by a public hospital agency, or financed in whole or in part by obligations issued by a public hospital agency, and used, or to be used when completed, as hospital facilities” … “shall be exempt from all taxation.”

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Ohio Hospital Facility Exemption

• O.R.C. 140.01(E): 'Hospital facilities' means buildings, structures and other improvements,

additions thereto and extensions thereof, furnishings, equipment, and real estate and interests in real estate, used or to be used for or in connection with one or more hospitals, emergency, intensive, intermediate, extended, long‐term, or self‐care facilities, diagnostic and treatment and out‐patient facilities, facilities related to programs for home health services, clinics, laboratories, public health centers, research facilities, and rehabilitation facilities, for or pertaining to diagnosis, treatment, care, or rehabilitation of sick, ill, injured, infirm, impaired, disabled, or handicapped persons, or the prevention, detection, and control of disease, and also includes education, training, and food service facilities for health professions personnel, housing facilities for such personnel and their families, and parking and service facilities in connection with any of the foregoing; and includes any one, part of, or any combination of the foregoing; and further includes site improvements, utilities, machinery, facilities, furnishings, and any separate or connected buildings, structures, improvements, sites, utilities, facilities, or equipment to be used in, or in connection with the operation or maintenance of, or supplementing or otherwise related to the services or facilities to be provided by, any one or more of such hospital facilities”

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Practice Pointers for Real Property Exemption

• Burden of Proof is on the Applicant
• Assertions in Notice of Appeal to Board of Tax Appeals are not

adequate evidence.

• Create a strong Statutory Transcript before the Tax Commissioner.
• Submit evidence at a hearing before the Board of Tax Appeals.
• United Community Brethren Church, BTA 2018‐450 (7/18/2019).
• Authentic Life Ministries, BTA 2018‐1171 (8/29/2019)

Multiple Sections of the Ohio Revised Code May Apply

• Assert all possible statutory exemptions.
• Do not focus on just one, when several apply (i.e., ORC 5709.07 and

5709.12).

• Board of Education of South‐Western City School District, BTA 2017‐504.
• Owner relied only on 5709.07 and BTA had no jurisdiction to consider

5709.12.

• City of Toledo, BTA 2017‐956 (6/24/2019)
• Hanger leased to Experimental Aircraft Association did not qualify

under 5709.12. Too late to seek exemption under 5709.08 or 4582.46.

• Jurisdiction limited to what was claimed at time of application.

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Exemption Statutes are Narrowly Construed

• Structure is important.
• Beware of for‐profit LLCs, even if disregarded for federal income

tax purposes.

• Columbus City School BOE, BTA 2018‐298 (9/5/2019).
• Use of for‐profit LLC to own land.
• For‐profit LLC is an “institution”, but the land did not qualify

because LLC used the property to lease to others.

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Exempt Statutes for Real Property is Not Self‐Executing

• Rice v. Islamic Center of Peace, Inc., Second District Court of

Appeals Case #28271 (8/23/2019).

• Depositor Foreclosure Program resulted in a foreclosure

complaint being filed.

• Center asserted that property was exempt because it was a

nonprofit corporation but never filed for exemption.

• Foreclosure did not violate due process or uniformity

provisions of Ohio Constitution.

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“Prospective Use” Doctrine

Under the “prospective use” doctrine, a mere dream

• f a future charitable use is insufficient. It is

important to document that progress is being made.

‒ United Community Brethren Church, BTA 2018‐450 (7/18/2019). Only $8,000 raised toward $40,000 of renovations. No substantive plan for raising needed funds. ‒ Authentic Life Ministries, Inc., BTA 2018‐1171 (3/04/2019). The record showed no evidence of substantive plans for use of property. ‒ Islamic Foundation of Central Ohio, Inc., BTA 2017‐1732 (3/25/2019).

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Residential Use

A Distinctly Residential Use of Real Property Generally Defeats a Claim for Charitable Exemption.

‒ OTR Living Water Ministry, BTA 2018‐571 (9/01/2019). Residential portions taxable, but other floors also taxable because OTR did not establish that the administrative functions primarily benefitted the community. ‒ Board of Education of the Columbus City School District, BTA 2017‐2147 and 2048 (7/29/2019). Leasing residential properties to “disadvantaged” persons did not qualify. ‒ Heartland Christian Center, Inc., BTA 2017‐1172 (2/05/2019). A husband and wife formed a ministry and lived on the property.

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Homes for the Aged

Life‐Care Requirement for Homes for the Aged.

• Antonine Maronite Sisters of Youngstown, Inc., BTA 2018‐25, 2018‐63

(January 7, 2020).

• Tax Commissioner denied exemption under 5709.12/5701.13(B)

because resident agreement permitted removal for failure to pay, in violation of Life‐Care Requirement.

• BTA reversed based on totality of circumstances.
• Sisters used a donated form document.
• Sisters testified that their religious order would never remove a

resident for failure to pay.

• Sisters amended the agreement immediately.
• Sisters never removed a tenant.

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Other Exemption Cases

‒ Fresh Fruits, Inc., BTA 2017‐1086 (2/25/2019). Property operated as a Christian‐based daycare. To be exempt under 5709.07 (house of public worship), property cannot be merely supportive of or incidental to public worship. ‒ The Literary Club, BTA 2017‐985 (7/22/2019). Activities are not charitable in nature because property is not open to the public and activities solely benefit Club members. ‒ Islamic Foundation of Central Ohio, Inc., BTA 2017‐1732 (3/25/2019). Islamic Center met burden of proof under 5709.07 because primary purpose was for public worship. Contention by Tax Commissioner and BOE that building is more community‐based than religious based was rejected.

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Revisit Lessons from Public Worship Exemption Case

• The Tax Commissioner denied the public worship exemption for a Christian radio station when

it moved into a new facility. The BTA affirmed the denial, but the Ohio Supreme Court

• reversed. Christian Voice of Cent. Ohio v. Testa, Oh. Supreme Ct., 147 Ohio St.3d 217, 2016‐

Ohio‐1527 (April 14, 2016) ‒ The 4‐3 majority found that the exemption should be allowed for property used to

• perate the Christian radio station because the primary use of property is for public

worship and not for profit. O.R.C. 5709.07(A)(2) ‒ Justice Sharon L. Kennedy wrote in her opinion that the radio station “has dedicated all its land and buildings to charity and religion, and … [has] the necessary attributes of a church.” ‒ Public worship for purposes of the exemption is “the open and free celebration or

• bservance of rites and ordinances of a religious organization.”

‒ The Court found that the real property must be used in a “principal, primary, and essential way to facilitate public worship” which can be met even when there are “auxiliary buildings or portions of building” when the primary building qualifies. ‒ Dissenting opinion written by Chief Justice Maureen O’Connor disagreed that the radio station was really a house of worship.

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Sales Price as Evidence of Value

• Plain Local Schools v. Stark County BOR, Fifth District Court
• f Appeals 2019‐Ohio‐1746 (8/23/2019).
• Appeal to Supreme Court denied 9/3/2019
• Abbey Church Village, BTA No. 2017‐1055 (1/28/2019).
• Re‐crediting sales transaction was found unreliable but

not because of ownership before and after the sale

• BTA used components of appraisals from both owner

and BOE along with actual gross income from the prior year

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Method and Timeliness of Appeals

• M&F Lexington v Franklin County BOR, Tenth District Court of

Appeals 2019‐Ohio‐2022 (5/23/2019).

• Affidavits were found as insufficient evidence
• A receipt showing the date of mailing via a statutory allowed

method was required

• Upper Arlington v McClain, Ohio Supreme Court 2019‐Ohio‐1726

(5/9/2019).

• Distinction made between appealing valuation versus

exemption

• Statutory change, effective 4/5/2017, for notifying Tax

Commissioner appellees; ORC 5717.04

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Miscellaneous Updates

• Property Tax Exemption

‒ Partial exemption for child care centers enacted by the recent Budget Bill (H.B. 166). ‒ Effective for tax year 2019 and thereafter ‒ Phased partial exemption applies if serving families that receive public assistance

• 50% exemption if 25% but less than 50% of children reside in

households receiving public assistance

• 75% exemption if at least 50% of children reside in households

receiving public assistance ‒ Previously, child care centers needed to qualify under other exemptions such as charitable purpose

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Miscellaneous Updates

• SUT

‒ Computer cabling change – updated Info. Rel. ST 1999‐01 ‒ New nexus standards – updated Info. Rel. ST 2001‐01/ H.B. 166

• CAT

‒ New nexus standards – updated Info. Rel. CAT 2005‐02

• Municipal

‒ Centralized filing election – 1st day of 3rd month

• Vapor tax

‒ See Info. Rel. XT 2019‐02 and H.B. 166

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Questions?

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Contact information

Jeffrey L. Stansberry, CPA, MT Tax Manager, Corporate Finance Ohio Health Jeffrey.Stansberry@ohiohealth.com Chris Swift Partner Baker Hostetler Cswift@bakerlaw.com Stephen Palmer Senior Manager, SALT Plante Moran Stephen.Palmer@plantemoran.com

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