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How did an interest in healthcare policy lead Robert Platt to a career in the law? Find out more>

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Envision to Sell to KKR for $9.9 Billion

We represented Envision Healthcare Corporation (NYSE: EVHC) in its definitive agreement to sell to KKR in an all-cash transaction for $9.9 billion, including debt. KKR will pay $46 per Envision share in cash to buy the company, marking a 32 percent premium to the company's volume-weighted average share price from November 1, when Envision announced it was considering its options. The transaction is expected to close the fourth quarter of 2018. Read more


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Thought Leadership

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Six Things to Know Before Buying a Physician Practice spotlight

Dermatology, ophthalmology, radiology, urology…the list goes on. Yet, in any physician practice management transaction, there are six key considerations that apply and, if not carefully managed, can derail a transaction. Download the 6 Things to Know Before Buying a Physician Practice to keep your physician practice management transactions on track.

Click here to download the guide.

State & Local Tax Attorneys Examine States' Use of Cost-of-Performance Sourcing to Generate Income

State Tax Notes

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March 13, 2018

Bass, Berry & Sims attorneys Mike Sontag, Steve Jasper, and Michael Cottone authored an article for State Tax Notes examining the "increasingly aggressive and inconsistent positions" states are taking regarding cost-of-performance sourcing (COP) and offering suggestions for taxpayers looking to push back against this trend. 

In the article, the authors analyze how "state taxing authorities have sought to take advantage of the uncertainty inherent in the COP standard in several ways," including:

  1. Distinguishing between direct and indirect costs;
  2. Labeling some items as third-party costs;
  3. Choosing between transactional and operational approaches to identifying income-producing activities; and
  4. Selectively imposing alternative apportionment.

Recognizing that the "fundamental problems in the COP method are rooted in the states' incentives to maximize income" and that motivation is unlikely to change, the authors also evaluate remedies states can implement – such as market-based sourcing or proportional COP tests – to avoid many of the problems associated with COP.

The full article, "'Heads I Win, Tails You Lose' Sales Factor Sourcing," was published by State Tax Notes on March 12, 2018, and is available online (subscription required).


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