IRS Ruling Spells Good News For Captive PCs

Law360, New York (February 20, 2015, 11:22 AM EST) -- The IRS recently issued PLR 201451009 permitting a practice management company and two "captive" professional corporations to file a consolidated federal income tax return as members of an affiliated group under Internal Revenue Code §1504(a), notwithstanding that the management company did not own any shares in the PCs. Every company that uses a captive PC business model, including health care systems, corporate dental chains, health care staffing companies, and professional management companies, should consider this private letter ruling and the potential tax planning opportunities....

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