Recovering $15M+ in Specialty Payroll Tax Credits Across a 25-Entity Healthcare Network

A complex group of 25 related healthcare entities, with common ownership and intercompany relationships, engaged Occams to evaluate its eligibility for Specialty Payroll Tax Credits across the entire structure. Potential claims exceeded $15 million.

The challenge was to evaluate each entity independently, avoid commingling risk across the group, and ensure claims were filed only where the eligibility requirements were genuinely met. The group also faced significant IRS processing issues after filing, incorrect address records for almost all entities left Specialty Payroll Tax Credits refund checks undelivered, and in some cases cancelled outright.

Strict entity-level validation

We analyzed the ownership structure and relationships across all 25 practices to determine appropriate tax treatment. To establish a supportable basis, we meticulously documented the practical operational impacts across the network, including staffing constraints, reduced capacity, increased labor costs, shortened hours, and supply chain disruptions.

Maximizing defensible claims

We calculated and filed claims strictly for the 23 eligible entities, deliberately excluding the two practices that did not meet the rigorous eligibility requirements. This ensured the maximum possible benefit while keeping the entire position highly defensible under applicable IRS rules.

Tax controversy and administrative resolution

To solve the check delivery failures, we identified the specific address record errors preventing the refunds from reaching the client. We prepared and submitted Form 8822-B to correct the business addresses and Form 3911 to request the immediate reissuance of the missing checks.

Resolving the IRS processing failures

Occams identified the specific IRS address issues preventing refunds from reaching the client, then prepared and submitted Form 8822-B, Form 3911, and entity-specific correspondence to correct the records and request reissuance of the missing checks.

Tracking every reissuance to completion

Occams worked closely with the Taxpayer Advocate Service and the client's authorized designee to track and resolve the outstanding refunds, maintaining regular communication with the client and confirming each reissuance as it landed.

We successfully navigated both the complex multi-entity eligibility rules and the broken IRS refund process.

Every single affected refund check was successfully reissued and delivered. The client received the full $15 million due for the 23 eligible entities, plus approximately 24% additional interest directly from the IRS. By intentionally excluding the two ineligible entities, the analysis provided a fully documented approach to evaluating complex ownership structures and defending the claims.

Most importantly, securing this capital supported the client's aggressive growth trajectory. The network successfully expanded from 25 practices to 62 practices, leveraging a structured approach to tax strategy to fuel its ongoing nationwide scale.

Advocacy and tracking

We worked closely with the Taxpayer Advocate Service and the client's authorized designee to track the outstanding refunds. We maintained constant communication with the client, promptly verifying every single check reissuance to ensure the funds actually landed in their accounts.