On November 16, 2007, an IRS official announced that the IRS intends to release another version of the draft redesigned Form 990 in December, and that the new version will contain many changes to both the core form and its various schedules (so that in many respects it will not resemble the form that was released last June).

It was also announced, however, that the IRS "remains committed to the content, philosophy, and structure, and format of the form." It was said that most of the comments that were received by the IRS after release of the initial draft form relate to the new Schedule H, with many of those comments being critical of the decision by the IRS to model the community benefit section of Schedule H on the Catholic Health Association model. It was said the IRS has not come to any final decisions as to how to deal with the community benefit section of Schedule H, except the decision to eliminate the billing questions from that Schedule.

It was also announced that when the revised version of the draft designed Form 990 is released in December, the IRS is prepared to accept comments only on whether there are any mistakes on the form. This is because the IRS is working on a very tight schedule and intends to place the revised Form 990 in use for tax years beginning in 2008. After revision of the redesigned Form 990 is complete, the IRS intends to focus on drafting instructions for the new form, which are anticipated to be released for public comment by the spring of 2008.

For Further Information

For additional information regarding this topic, please contact David M. Flynn, one of the other members of the Health Law Practice Group, or the attorney in the firm with whom you are regularly in contact.

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