§453 · Sell Medical Practice Defer Capital Gains

Selling Your Medical Practice Without the Year-One Tax Bomb

Physician roll-ups are the biggest M&A trend in healthcare. Privia Health, One Medical (Amazon), Optum (UnitedHealth), Tenet Healthcare, US Acute Care Solutions, Envision Healthcare, Sound Physicians, Surgery Partners, ChenMed, Iora Health, ApolloMD, regional MSOs — all paying 4-8x EBITDA for established practices. A $1M EBITDA practice = $4M-$8M sale.

§453 Mechanic — How the Money Flows

Buyer cash → Assignment Co. → A-rated carrier → You, on schedule

BUYER pays full cash at closing ASSIGNMENT CO. qualified entity, regulated purchases annuity A-RATED CARRIER A-Rated Carrier A+ rated · A.M. Best SELLER (you) paid on chosen 5-30 yr schedule Closing day — one wire, one assignment Gain recognized proportionally each year per IRC §453 (Treas. Reg. §15A.453-1)

For specialty practices (cardiology, GI, orthopedics, oncology), multiples run higher (6-12x EBITDA). A $2M EBITDA specialty practice = $12M-$24M.

The math — $5M medical practice sale

StateState rateLump-sum tax10-yr §453 taxDelta
California13.3%~$1.85M (37%)~$1.40M (28%)$450K
New York10.9%~$1.74M~$1.32M$420K
New Jersey10.75%~$1.73M~$1.31M$420K
Oregon9.9%~$1.68M~$1.27M$410K
Texas / Florida / Tennessee / Nevada / WA / WY0%~$1.19M~$0.90M$290K

Assumes $5M sale, 70% goodwill, 20% equipment, 10% supplies + AR.

Medical-practice tax wrinkles

  1. MSO / Friendly PC structure — most physician roll-ups use MSO-MSO with management services agreement. APA papers the §453. State medical board ownership rules don't affect §453 mechanic.
  2. Equipment §1245 recapture — EMR systems, imaging equipment (CT, MRI, X-ray), surgical instruments, exam tables — high recapture exposure year one. Allocate carefully.
  3. Specialty vs primary care — specialty (cardiology, GI, orthopedics) higher multiples and higher goodwill % than primary care. Better §453 leverage.
  4. Concierge / DPC (direct primary care) model — different valuation methodology, often higher goodwill % due to recurring membership fees.
  5. Insurance contracts and Medicare provider number transfer. Affects timing not §453 mechanic.
  6. Stark Law / Anti-Kickback Statute compliance — sale must comply. Buyer's counsel handles.
  7. Receivables collection post-close — typically allocated to seller; treatment matters.
  8. State medical board notice requirements — vary by state.

When this fits

  • $1.5M+ practice value
  • Goodwill-heavy deal (most MSO deals qualify)
  • Sophisticated buyer with M&A counsel (PE-backed platforms have all done §453 before)
  • Physician retiring or scaling back (not 100% rollover)

When it doesn't

  • Mostly equipment sale
  • Solo without team
  • 100% rollover into MSO equity

How I work

Hans Goldstein, IRC §453 specialist. an A-rated Fortune 500 carrier / an A-rated Fortune 500 carrier / an A-rated Fortune 500 carrier / an A-rated Fortune 500 carrier — 50 states. Free 15-min fit-check call. Bring practice EBITDA, equipment basis, prior depreciation, offer terms, residency state.

Frequently asked

Q: My MSO offer is 60% cash / 40% rollover. Does §453 work? A: Yes — on the cash portion. The rollover equity has its own §351-like deferral mechanic. Two layered deferrals.

Q: I'm a primary care doc with ~$400K EBITDA. Too small? A: Maybe — if you can stretch the sale price to $1.5M+ with optional carve-outs (real estate, ancillary services), §453 fits. Below that the math doesn't move the needle.

Q: Optum / Privia — do they paper §453? A: Yes, routinely. Their M&A counsel knows the structure.

Hans Goldstein, NPN 20602398

📘 Get the free Seller's Guide to §453 + a fit-check

A plain-English guide for sellers: how a structured installment sale defers the tax when you sell a business, practice, or property — the math, the alternatives, and how to know if your deal fits.

Drop your info — instant PDF download + within 1 business day Hans will email a preliminary read on which structure fits your deal. No retainer. Carrier compensates the broker — not you.

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📞 Hans Goldstein · 615-808-9731 · CA Insurance License #4322192 · Independent §453 specialist · Goldstein & Co. LLC

Educational. Not tax or legal advice.

Run your specific numbers

The calculator runs your sale through real 2026 federal + state tax brackets and shows §453 savings vs lump sum side-by-side.

Run the calculator → 615-808-9731