Recovering $15M+ in Statutory Tax Credits to Fuel Nationwide Healthcare Expansion 

A complex healthcare and life sciences group of 25 related entities engaged Occams to evaluate its eligibility for specialty tax credits. With common ownership and intricate intercompany relationships, the potential claims exceeded $15 million. 

The group faced a dual challenge. First, they needed to accurately determine eligibility across all 25 entities while avoiding commingling risks. Second, they encountered severe IRS processing issues after filing. Incorrect IRS address records for nearly all entities resulted in refund checks being returned as undeliverable and, in several cases, completely cancelled.

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.

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. 

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. 

Tax Strategy and Specialty Credits Team, Occams Advisory

Structuring complex corporate tax positions, resolving institutional discrepancies, and capturing statutory credits to maximize capital recovery for healthcare enterprises. Stop leaving millions in rightful capital behind due to bureaucratic gridlock. Take control of your balance sheet and claim the growth your enterprise earned today.