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202 - Income Tax Planning E Stepped-up basis (1) Assets included in a taxable estate of a decedent receive a stepped-up basis The receivers of the bequests receive a basis in those assets equal to the fair market value at date of the decedent s death or, alternately, six months after the death The step-up in basis is available only for those assets in the taxable estate If assets are kept out of the estate, such as gifts, they will not enjoy the step-up in basis (2) Common law states have a step-up basis for half of the assets; a step-up in basis for the decedent s share of ownership but not for the survivor s share (3) Community property states have a full step-up in basis For tax purposes at death, the new cost basis is the fair market value (FMV) at the date of death for both halves of the community property, even though only one-half is included in the decedent spouse s estate (4) Property owned solely by a decedent generally receives a full step-up basis for the person who acquires it Example: Bart owned stock in XYZ, which he purchased for $1,000 in 1935, until his death in 2003, when it passed on to his son John At Bart s death, the stock was worth $250,000 John kept the stock for six months and sold it for $270,000 John has a realized long-term capital gain of $20,000 between the sale price and the date-of-death value (because it was acquired from the decedent, the holding period for the property is automatically considered long term) (5) For joint tenancy with right of survivorship, two rules are followed in deciding what is included in a decedent s estate and the surviving owner s new basis (a) Husband and wife rule Where the only joint tenants are husband and wife, half of the FMV at the date of death is included in the decedent s estate and the surviving spouse s new basis will equal half the total predeath basis and half the FMV at the date of death (b) Consideration furnished rule Where joint tenants include nonspouses, the decedent s gross estate includes that proportion of the property as the decedent s share of the consideration bears to the total consideration The new basis for each surviving co-owner s interest is his or her old basis plus an increase by the amount included in the decedent s estate split equally among the surviving joint tenants (6) For tenancy in common, the surviving spouse s cost basis at death is the amount included in the deceased spouse s estate If left to a co-owner, the new basis is his or her old basis plus an increase by the amount included in the decedent s estate Example: Lyle, Joel, and Dan purchased property as tenants in common Of the $100,000 purchase price, Lyle aid $50,000 and took a 50 percent interest, Joel paid $30,000 and took a 30 percent interest, and Dan paid $20,000 and took a 20 percent interest Years later when Joel died, the property was worth $250,000 and his estate included $75,000 because he owned a 30 percent interest If Joel left his interest to his widow, Betty, her basis would be $75,000 If he instead left his interest to co-owner Dan, Dan s total basis in the 50 percent interest he would then own would be $95,000 ($75,000 plus his $20,000 contribution) F Impact of community property and common law on basis (1) Community property states provide a decided advantage over common law states in regard to basis adjustments at death.

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This is an acceptable practice under GAAP, based on ARB No 43 s criteria However, HCOs require providers that report internally designated assets under this caption to distinguish them from assets whose use is contractually limited by external parties (This distinction is considered important because of the degree of control the organization is able to maintain over the use of those funds) This may be accomplished either through disclosure in the notes to the nancial statements or by presenting separate amounts on the face of the balance sheet ARB No 43 states that where funds are set aside for the liquidation of long-term debts, payments to sinking funds, or similar purposes are considered to offset maturing debt which has properly been set up as a current liability, they may be classi ed as current assets Similarly, HCO explicitly requires a portion of malpractice self-insurance funds equal to the amount of assets expected to be liquidated to pay malpractice claims classi ed as current liabilities to be classi ed as current assets A note generally is included in the summary of signi cant policies (or separately) describing the purpose of the limited-use assets (ii) Governmental Providers Governmental health care entities report these types of limitations as restrictions when they arise from external sources or are externally imposed, as discussed in Subsection 363(a)(ii) Management s designation of net assets (ie, internal limitations indicating that management does not consider them to be available for general operations) are not reported on the face of the balance sheet (c) AGENCY TRANSACTIONS Health care entities may act as agents for other parties; as such, they receive and hold assets that are owned by others An example of this would be patients or residents funds These are funds held by the facility for the patient s or resident s own personal use, such as for purchasing periodicals, making trips outside the facility, or for other incidentals Usually, these funds are kept in an account separate from the facility s own cash accounts In accepting responsibility for these assets, the entity incurs a liability to the owner either to return them in the future or to disburse them to another party on behalf of the owner Transactions involving agency funds (eg, disbursements, interest earned) should not have any economic impact on the provider s operations Consequently, they should not be included in the provider s income statement Fund-raising foundations may act as agents in accepting donations on behalf of related HCOs These situations are discussed in Subsection 363(k)(iv) (d) REVENUE OF HEALTH CARE FACILITIES A unique aspect of health care operations is that revenue transactions primarily involve more parties than the traditional buyer and seller As many as four parties may be associated with a revenue transaction involving a health care provider These include: (1) the individual who receives the care; (2) the physician who orders the required services on behalf of the patient; (3) the health care entity that provides the setting or administers the treatment; and (4) a third-party payer that pays the health care entity, physician, or both on behalf of the patient The third-party payer may be a government program such as Medicare or Medicaid and/or a commercial insurer such as a managed care plan, a commercial insurance company, a Blue Cross plan, or a preferred provider organization (PPO) The extent to which third-party payers are involved in paying for services varies by type of health care facility For hospitals, rehabilitation facilities, and home health companies, the majority of services provided are paid for by third-party payers In the nursing home sector, roughly half of the patients are considered private pay (ie, the patient or their family pays for the care); for the remainder, Medicaid is the dominant third-party payer (for care provided to low-income individuals) Little commercial insurance coverage presently exists for nursing home care, and Medicare provides very limited nursing home bene ts only for short stays In CCRCs, entrance fees and monthly service fees are paid by the residents themselves, and third-party payer involvement s limited to payment of some services that may be provided in the skilled nursing care portion of the facility.

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