IRS Says State Health System’s Self-Insurer Doesn’t Incur Tax

Aug. 8, 2025, 2:55 PM UTC

A state-founded company that insures a state-run healthcare system’s medical professionals doesn’t have income that would be subject to tax, the IRS says.

The company provides “an essential governmental function” in providing the insurance, and so the income is excludable from gross income pursuant to Section 115(1), the IRS said in a May 1 private letter ruling made public Friday.

The unidentified nonprofit mutual benefit corporation is designed to provide liability insurance and risk-mitigation services to the healthcare providers who work for the state health system, which provides patient care in specialized services and care for indigent citizens.

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