IRC Section §303 Stock Redemptions

Understanding Physician Estate Planning

By Lawrence E. Howes; CFP™
By Joel B. Javer; CFP™

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A family business or medical practice may make up the majority of a physician’s estate. Unfortunately, although the practice does have value, it may have very little cash.   

Recognizing the Dilemma 

In recognition of the closely held business owner, the IRS allows stock in the company to be redeemed to pay federal and state death taxes, generation-skipping transfer taxes, and funeral and administration expenses.  

There are few tax-deductible ways of getting money out of a corporation and salaries and business expenses head the list.

Example:

For example the IRS maintains that, if a business is at least 35 percent of your adjusted gross estate, the business owner can redeem stock to pay for approved expenses. Since you get a step-up in basis at death, the shares redeemed should not generate a capital gain. 

The transaction is deemed a sale of a capital asset, and not a dividend.  (A dividend is not deductible so it is taxable to the corporation as well as taxed to you personally upon receipt). 

Assessment 

The strategy of an Internal Revenue Code § 303 redemption is prudent.  However, there must be cash available to redeem the stock. Typically, a life insurance policy is purchased to provide the cash for the redemption. 

Conclusion 

Please opine and comment if you have ever considered or used this strategy; and what was the result? 

Book info: http://www.jbpub.com/catalog/0763745790/ 

Linguistics: www.HealthDictionarySeries.com 

Related: Funding IRC Section 303 to Pay Estate Taxes and Expenses

http://www.nysscpa.org/cpajournal/1997/0597/depts/pfp.htm

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Introduction to Healthcare Economics

White-Paper: healthcare_economics

From the Public Health Management and Policy Department

By Ben Hagopian

By Matt Wilson

To understand health economics, it is first critical to understand the basics of economics; or the “dismal-science.”  

At its most basic level economics can be defined as the study of choices, made by individuals or groups, when resources are limited. The concept is better known as “scarcity” and is the backbone of all economic thinking. 

This white-paper on healthcare economics is a basic dissertation by two Master’s of Public Health [MPH] students from Case-Western Reserve University. 

Although theoretical in nature, it is a good review of fundamental principles with recent domestic policy changes; complete with illustrative figures. 

The one disappointment was its failure to mention or reference, Kenneth J. Arrow PhD – the youngest Nobel Prize winning economist – of 1972. For more than fifty years he has been one of the most listened to of all practicing economists and is arguably known as the father of “health economics.”  

And, for a more pragmatic approach to augment this primer – with real world case models – the listed resources are suggested. 

Nevertheless, all readers and ‘”Executive-Post” subscribers are encouraged to review this understandable treatise. It will be well worth your time. 

Hope Rachel Hetico; RN, MHA, Certified Medical Planner

iMBA, Inc – Atlanta, Georgia USA

www.MedicalBusinessAdvisors.com 

More: http://www.springerpub.com/prod.aspx?prod_id=23759 

Individual: http://www.jbpub.com/catalog/0763745790/ 

Risk Management: www.jbpub.com/catalog/9780763733421/ 

Institutional: www.HealthcareFinancials.com 

Terms: www.HealthDictionarySeries.com