Thomas' practice emphasizes tax planning, nonprofit law, and health care law. His clients include national hospital systems, research organizations, education organizations, private foundations, colleges, universities, associations, social welfare organizations and governmental entities.

Clients turn to Thomas for:
  • Mergers and acquisitions
  • Joint ventures of nonprofit and for profit entities
  • Nonprofit governance issues
  • Compliance with private foundation rules
  • Unrelated business income planning
  • Fundraising programs
  • For-profit subsidiary planning
  • Planning to avoid private insurement, private benefit and the intermediate sanctions
  • Nonprofit system planning to maximize tax compliance and tax efficiency for taxable entities and activities in the system
Thomas is a frequent writer and speaker on nonprofit law and tax topics. Three of his many publications include co-authoring the Tax Management Portfolio’s “Private Foundations – Distributions (Sec. 4942)” published by the Bureau of National Affairs; co-authoring "The New Form 990: Law, Policy, and Preparation;” and co-authoring "Nonprofit Law for Colleges and Universities Essential Questions and Answers for Officers, Directors and Advisors."
  • Obtained tax exemption for complex multi-tiered super-parent of two health systems.
  • Structured acquisition of multiple technology and education companies, both for-profit and nonprofit, for an Educational Institution utilizing a number of acquisition techniques including triangular mergers, asset acquisitions and various stock transactions.
  • Ongoing planning for complex hospital and education systems to maximize tax compliance for tax-exempt entities and tax efficiency for taxable entities and taxable activities in systems.
  • Structured numerous joint ventures for multiple health care systems with multiple tiers of entities involving for-profits and nonprofits.
  • Creation of a State Authority to spin-off hospital operations from the State and securing a private letter ruling from the IRS recognizing the Authority as a tax-exempt integral part of the State.
  • Structured research consortium of nonprofits and governmental organizations utilizing a supporting organization structure and a for-profit technology transfer subsidiary and obtained a favorable private letter ruling to support structure.
  • Regularly provide counsel to hospital and health system clients on unrelated business income consequences of various activities operated directly by the exempt organizations and by flow-through partnerships and limited liability companies.
  • Counsel hospitals and health systems with MOB development and private activity use, unrelated business income and acquisition indebtedness rules related to ownership and leasing of MOB space.
  • Tax and business planning for systems utilizing various types of tax-exempt organizations and taxable entities.
  • Structured multiple acquisitions and sales of various business activities and related entities of multiple health care systems.
  • Structure of management agreements and other service provider arrangement with both related and unrelated organizations.
  • Executive Compensation planning and compliance with governance procedures and tax regulations.
  • Comprehensive governance and policy planning for multiple tax-exempt organizations.
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