United States: IRS Ruling Permits Inclusion Of “Friendly PCs” In Consolidated Federal Income Tax Returns

On December 19, 2014, the Internal Revenue Service (“IRS”) issued a private letter ruling (the “Ruling”) allowing corporations that manage physician practices through a so-called “friendly physician” arrangement to treat the physician practices as members of the corporations’ consolidated tax group for U.S. federal income tax purposes. The Ruling is significant because it demonstrates that management companies, which must use the friendly physician structure in states that prohibit the corporate practice of medicine, can […]

By |February 19th, 2015|

United States: Abusive Small Captive Insurance Companies Added To IRS “Dirty Dozen Tax Scams”

For the first time, the Internal Revenue Service (IRS) has included certain small captive insurance companies (CICs) in its annual list of “Dirty Dozen Tax Scams.” On February 3, 2015, the IRS released IR-2015-19, which identified the use of abusive small CICs as one of this year’s “Dirty Dozen.” The release contains a specific discussion of abusive small CICs and lists several facts that the IRS believes are indicative of abuse.

The insured owners of […]

By |February 18th, 2015|

United States: Details Of Governor Bill Haslam’s “Revenue Modernization Act” Emerge: Broad-Sweeping Tax Proposals To All Major Tennessee Taxes

The Administration introduced the “Revenue Modernization Act” on February 11 in the Senate Finance Committee, and the proposal includes numerous modifications to all Tennessee’s major taxes, including economic nexus, click-thru nexus, market sourcing, sales tax on remotely accessed computer software, and expansion of the business tax.

Governor Bill Haslam announced during the annual state-of-the-state address in Tennessee on February 10 that the Administration would introduce a “Revenue Modernization Act” during the current legislative session to […]

By |February 18th, 2015|