12-Month Rule & IRC §267(f) for MSOs | Guardian Tax
Applying the 12-Month Rule and IRC §267(f) to Management Service Organizations (MSOs) Introduction: Timing Rules and Controlled Groups In the world of tax planning for healthcare and professional services, management service organizations (MSOs) often operate within controlled group structures. Timing the deduction of prepaid service income can make a substantial difference in a company’s tax […]
Managing Double Taxation Risk in C-Corporation MSO Structures
Managing Double Taxation Risk in C-Corporation MSO Structures Introduction to Double Taxation in C-Corp MSO Models Double taxation is a well-known concern when structuring healthcare or business operations through a C-Corporation under a Management Services Organization (MSO). This structure offers strategic tax advantages, but without proper planning, profits may be taxed twice—once at the corporate […]