IRS Open to Suggestions on ‘Friendly Doctor’ Structure Guidance

The IRS is still studying and seeking comments on beneficial ownership in ‘friendly doctor’ structures, according to an agency statement provided to Bloomberg Tax.

It is becoming increasingly common for medical practices to be acquired by larger corporate groups, but in some states licensed professionals such as doctors or veterinarians are required to own and control their practices. In a ‘friendly doctor’ structure, a physician-owned professional corporation manages the administrative control of a medical practice.

That set-up raises questions for taxpayers and tax professionals, including whether it meets the definition of control under tax code Section 1504(a) for affiliated ...