IRS Closes Audit on Florida's Adventist Health Bonds

WASHINGTON — The Internal Revenue Service has closed an audit of the Highlands County Health Facilities Authority’s 2005 refunding bonds with no change to their tax-exempt status.

The Florida authority disclosed the outcome of the audit in an event notice filed Tuesday with the Municipal Securities Rulemaking Board’s online EMMA ­system.

The IRS opened its audit of the bonds in December. The debt was issued for the Adventist Health System/Sunbelt Obligated Group.

The 2005 Series C bonds were part of a $325.3 million deal that included new-money and refunding bonds. The refunding bonds were issued to refund 1993, 2000 and 2001 bonds.

In an Aug. 12 letter to the health authority, the IRS said it has closed its audit examination “with no change to the position that interest received by bondholders is excludable from gross income” under the tax code.

Based in Winter Park, Fla., Adventist Health is a nonprofit provider that operates 36 hospitals and philanthropic foundations in 10 states. It is the largest nonprofit Protestant health care organization in the country, according to Fitch Ratings.

Last September, Adventist Health System  merged with Tampa-based University Community Health. The UCH acquisition included the 500-bed Medical Center, two other hospitals, a long-term acute care hospital and a heart institute, Fitch said.

Ziegler Capital Markets Group and Citi were co-underwriters for the 2005 deal. Chapman and Cutler LLP was the bond counsel, with certain legal matters passed onto Swaine, Harris & Sheehan P.A.

The offering’s underwriters were represented by Sonnenschein Nath & Rosenthal LLP.

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Healthcare industry Tax Washington Florida
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