Loretto Hospital

Schedule D, Part X, Line 2 FIN 48 (ASC 740) footnote

“The Hospital and the Foundation are not-for-profit corporations as described in Section 501(c)(3) of the Internal Revenue Code (the Code) and are exempt from federal income taxes on related income pursuant to Section 501(a) of the Code. Westside does not consider itself to be engaged in a United States trade or business and therefore, is not considered subject to United States income taxes. If Westside should be considered to be engaged in a United States trade or business, it could be subject to federal income tax, federal alternative minimum tax, and branch profits tax. Under the Cayman Islands Tax Concessions Law, the Governor in Cabinet issued an undertaking to Westside on November 11, 2014 exempting it from all local income, profit, or capital gains taxes. The undertaking has been issued for a period of 20 years and, at the present time, no such taxes are levied in the Cayman Islands. Accordingly, no provisions for taxes are made in these financials. Accounting principles generally accepted in the United States of America require management to evaluate tax positions taken by Loretto Hospital. A tax position is recognized as a benefit only if it is "more likely than not" that the tax position would be sustained in a tax examination, with a tax examination being presumed to occur. The amount recognized is the largest amount of tax benefit that is greater than 50% likely of being realized on examination. For tax positions not meeting the "more likely than not" test, no tax benefit is recorded. Loretto Hospital does not expect the total amount of unrecognized tax benefits to significantly change in the next 12 months. Due to its tax-exempt status, Loretto Hospital is not generally subject to U.S. federal income tax or state income tax. Loretto Hospital is subject to routine audits by taxing jurisdictions; however, there are currently no audits for any tax periods. Interest and / or penalties related to income tax matters are recognized in income tax expense. No amounts were accrued for interest and penalties at June 30, 2017 or 2016. Management believes it is no longer subject to income tax examinations for the years prior to June 30, 2014.”