Crh Health Services Inc

Schedule D, Part X, Line 2 FIN 48 (ASC 740) footnote

“CRH Health Care, Inc. and CRH Health Services, Inc. are exempt from income taxes pursuant to Section 501(c)(3) of the Internal Revenue Code. Accordingly, no provision for income taxes on qualifying activities has been made for these entities in the accompanying consolidated financial statements. However, certain entities and operations are subject to income taxes. Orthopedic Surgeons of Georgia, LLC, Emergency Physicians of Coffee County, LLC, and Coffee County Open Arms Clinic, LLC, are limited liability companies and treated as pass through entities for tax purposes. CRH Ventures, Inc. and Southeastern Managed Care, Inc. are taxable entities and are subject to federal and state income taxes. CRH Ventures, Inc. and Southeastern Managed Care, Inc. file separate federal and state income tax returns, and the taxable amounts are not significant to the consolidated financial statements. Coffee Regional Medical Center Segregated Portfolio is an exempted Segregated Portfolio Company that was incorporated under the provisions of the Companies Law of the Cayman Islands and has received an undertaking from the Cayman Islands Government exempting it from all local income, profits, and capital gains taxes. The System applies accounting policies that prescribe when to recognize and how to measure the financial statement effects of income tax positions taken or expected to be taken on its income tax returns. These rules require management to evaluate the likelihood that, upon examination by the relevant taxing jurisdictions, those income tax positions would be sustained. Based on that evaluation, the System only recognizes the maximum benefit of each income tax position that is more than 50% likely of being sustained. To the extent that all or a portion of the benefits of an income tax position are not recognized, a liability would be recognized for the unrecognized benefits, along with any interest and penalties that would result from disallowance of the position. Should any such penalties and interest be incurred, they would be recognized as operating expenses. Based on the results of management's evaluation, no liability is recognized in the accompanying consolidated balance sheet for unrecognized income tax positions. Further, no interest or penalties have been accrued or charged to expense as of December 31, 2023 and 2022 or for the years then ended. The System's tax returns are subject to possible examination by the taxing authorities. For federal income tax purposes, the tax returns essentially remain open for possible examination for a period of three years after the respective filing deadlines of those returns.”