Taxation of State Payments to Attract Health Care Professionals

State A has several programs to entice health care professionals to perform services in rural, low-income, and other underserved areas of the State. Participants need not have outstanding student or other types of loans to participate, and the available information indicates that they can spend the incentives as they wish. As presently structured, the programs represent employment incentives or compensation for agreeing to perform services within the State. The amounts paid under these programs are not received under a "State loan repayment or loan forgiveness program" as described in IRC Sec. 108(f)(4) , and so are taxable income. CCA 201104032.

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