IRS Chief Counsel Memorandum on Deductibility of PCOR Fees

Chief Counsel Memorandum concludes that PCOR fees (Patient-Centered Outcomes Research Trust fees) are deductible by the issurer as ordinary and necessary business expenses under Section 162.

Document Excerpt

This memo addresses whether fees paid by issuers of certain health insurance policies and plan sponsors of certain self-insured health plans to fund the Patient-Centered Outcomes Research Trust Fund (PCOR) are ordinary and necessary business expenses, and, thus, deductible business expenses.



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