Orrick Tax Talk 5 - Management Contracts

It is very common for organizations to outsource certain activities to non-employee based service providers that can perform the services in a more efficient way. Outsourcing is not a problem provided that the contract meets certain IRS safe harbor rules. Structuring management contracts to be safe harbor compliant is important for issuers and borrowers of tax-exempt debt, in order to avoid generating private business use. Ed and Larry review the safe harbors currently available to organizations until August 2017 (after which date new safe harbor requirements will apply) and describe the types of contracts that do and that do not create private business use.

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Other Tax Talk Videos
1. The ABC’s of Governmental Bonds
2. The ABC’s of 501(c)(3) Bonds
3. Private Business Use
4. Private Payments
5. Management Contracts
6. Sponsored Research Contracts
7. Private Activity Bonds
8. Tax Credit Bonds (video removed as tax credit bonds can no longer be issued)
9. Post-Issuance Tax Compliance
10. Change in Use/VCAP
11. IRS Audits
12. Allocation of Bond Proceeds and Floating Equity
13. Management Contracts – New 2017 Rules