Jackson Hospital Qalicb

A. Applicant was formed under the Florida nonprofit corporation act to serve as a type 3 functionally integrated supporting organization within the meaning of section 509(a)(3) of the internal revenue code of 1986, as amended (the code), treasury regulations section 1.509(a)-4(i), and notice 2014-4 that is operated in connection with and for the benefit of the Jackson county Hospital district, a public, non-profit independent special district established under chapter 2003-363 of the laws of Florida (the Hospital district). Applicant was formed to reduce the burdens of government by serving as a qualified active low-income community business or Qalicb (as defined in code section 45d(d)(2)) to facilitate the financing of (i) certain repairs to the Jackson county Hospital (the Hospital), which suffered significant damage as a result of hurricane michael in 2018, (ii) the relocation and expansion of the Hospital's nuclear medicine department, and (iii) the acquisition of medical equipment for use in the Hospital (the foregoing is collectively referred to in this application as the project). In connection with the project, applicant will lease the Hospital building and the real property on which the Hospital is located (the project property) pursuant to a long-term ground lease with the Hospital district. Applicant will then sublease the completed project (including the newly acquired equipment) back to the Hospital district pursuant to a sublease. The Hospital district will continue to operate the Hospital.