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 […]
The Sham Entity Doctrine & MSO Compliance: What You Need to Know
Key Questions on MSO Compliance and the Sham Entity Doctrine Understanding the IRS’s Approach to MSO Compliance A Management Services Organization (MSO) can be a valuable tool for businesses when structured correctly. However, the IRS has scrutinized MSOs that exist solely for tax avoidance. Below, we explore the key factors that distinguish a legitimate MSO […]
Protecting Privately Held Companies: The Critical Importance of Tax Opinions by Experienced Attorneys
Protecting Privately Held Companies: The Critical Importance of Tax Opinions by Experienced Attorneys The Problems Businesses Face Without Tax Opinions For business owners, particularly those managing privately held companies, the stakes of not obtaining a proper tax opinion can be devastating. Without the guidance of an experienced tax attorney, businesses face numerous risks: Exposure to […]
Why MSOs Aren’t Classified as Personal Service Corporations
Introduction When structuring a business, especially in industries involving professional services, understanding the tax classification of your entity is crucial. A common area of confusion is whether a Management Services Organization (MSO) qualifies as a Personal Service Corporation (PSC) under the Internal Revenue Code. Generally, an MSO is not considered a PSC; however, there are […]