The Thursday Report – 10.13.16 – Medicare Tax, Morrow on 2704, and More!

Updates to Our Comments on Revenue Procedure 2016-49

The Net Investment Income Tax (Medicare Tax) on Sale of an Active Business – The See-Through Rule and Other Nudity Considerations

Car 754 (Election), Where Are You? – The IRS Approves a Late-Filed 754 Election in PLR 201638009

Health and Information Technology by Pariksith Singh, M.D.

Richard Connolly’s World – Caring for Pets as Part of Your Estate Plan

Thoughtful Corner – The Vast Majority of Professionals Act Like Professionals

Humor! (or Lack Thereof!)

We welcome contributions for future Thursday Report topics. If you are interested in making a contribution as a guest writer, please email Stephanie at stephanie@gassmanpa.com.

This report and other Thursday Reports can be found on our website at www.gassmanlaw.com.

Quote of the Week

“My underlying strategy-execution bias: Act your way into thinking beats think your way into acting. The science behind that assertion is solid.”
– Tom Peters

Tom Peters is the maven of the guerrilla warfare style of making your business or profession as great as it can be. He is the author of several books on business management practices and is best known for the books Thriving on Chaos and In Search of Excellence, which he co-authored with Robert H. Waterman, Jr. In Search of Excellence was released in 1982 and quickly became a national best-seller. It can be viewed by clicking here. Today, Tom Peters continues to write and speak about personal and business empowerment and problem-solving methodologies.

Updates to Our Comments on Revenue Procedure 2016-49
by Alan Gassman and Christopher Denicolo

In the last Thursday Report, we published an Article describing the newly-released Revenue Procedure 2016-49 where the IRS indicated that it will not seek to invalidate QTIP elections made where portability is intended to be relied upon by taxpayers. This article can be viewed by clicking here.

We discussed our findings with Ed Morrow of Key Bank, and Ed added the following astute observation that will be part of an article that we will soon be publishing on the Leimburg Information Service.

The common wisdom for electing portability for small estates has mostly been, other than the Form 706 preparation cost, that the surviving spouse has “nothing to lose” by filing. But consider the ramifications of the new Revenue Procedure 2016-49.  The new procedure very clearly forecloses the IRS negating the QTIP election for any estate electing portability.

To illustrate how Revenue Procedure 2016-49 now creates an opportunity tax cost for smaller estates that elect unneeded portability, let’s take a hypothetical couple with husband having a $2,000,000 estate and wife having a $2,000,000 estate, both of whom leave their assets to each other in a QTIP-able trust. Husband dies, but after his death there is a bond or stock market correction and, by the time wife dies 2 years later, the assets have gone down in value to $1.5 million. If husband’s executor (probably the wife) had filed a Form 706 and elected both QTIP and portability, her estate is now ineligible to revoke the QTIP election pursuant to Revenue Procedure 2016-49. Her estate and beneficiaries receive a new, lower $1,500,000 basis. By contrast, had portability not been elected, her estate can use Revenue Procedure 2016-49 to revoke the QTIP election and preserve the additional $500,000 of carry over basis.

Consider what is more likely: clients winning the lottery and come into millions more dollars of wealth, or clients losing money on investments or having investments depreciate in value? Over the long haul, investments in a QTIP are likely to have higher fair market value at the surviving spouse’s death than cost basis, but not always.

This is not to say that electing portability for small estates is appropriate in some cases. However, it is more important to recognize that over utilizing QTIP merely for the second step up in basis has certain drawbacks, especially for combined estates less than or close to one exemption amount. For example, if our hypothetical couple above had simply used a traditional bypass trust with a formula general power of appointment or limited power of appointment triggering the Delaware Tax Trap, the survivor can safely elect deceased spousal unused exemption amount for the remaining $3,450,000 of the first dying spouse’s exemption without any ill effect, and the surviving spouse’s family can effectively get a carryover basis for any assets that have a basis higher than fair market value at the surviving spouse’s death, and a step up in basis for any assets with a basis lower than fair market value at that time. This is a much better result than if QTIP had been used, since QTIPs cannot parse inclusion between gain and loss assets and force a step down for any assets with basis higher than fair market value. Moreover, the bypass trust is much stronger for asset protection and income tax planning than a QTIP trust. A QTIP trust cannot shift income to lower bracket taxpayers or get more advantageous charitable income tax deductions that bypass trusts can exploit.

Thanks, Ed, for your insights on this topic!

The Net Investment Income Tax (Medicare Tax) on Sale of an Active Business – The See-Through Rule and Other Nudity Considerations
by Brandon Ketron, J.D., LL.M., CPA

Gain on the disposition of an interest in a Partnership or S Corporation is subject to the additional 3.8% Net Investment Income Tax only to the extent of the gain that would be taken into account if all the Partnership’s or S-Corporation’s property were sold for fair market value immediately before the disposition of the interest.  See 507-3rd: Income Tax Liability: Concepts and Calculation, Detailed Analysis, E. Net Investment Income Tax.

In order to determine the amount of gain subject to the additional 3.8% Net Investment Income Tax, the amount and character of gain from a deemed sale of all the assets of the S-Corporation must be determined.

Assets used in the ordinary course of a business in which the partner or shareholder materially participates are not subject to the 3.8% tax, while assets that are not used in the ordinary course of a trade or business or the partner or shareholder does not materially participate will be subject to the 3.8% tax.

Amounts held as working capital are considered to be assets used in the ordinary course of a business and thus not subject to the additional 3.8% tax.  Income or gain which is attributable to the investment of working capital is not considered to be derived in the ordinary course of a trade or business, and therefore is subject to the additional 3.8% tax.

For example, A and B each own 50% of the stock of AB, Inc., an S Corporation in which they are both active participants.  A and B each sell their interest in AB, Inc. for $250,000 and have an adjusted basis of $200,000.  Therefore, A and B each have a capital gain of $50,000.

AB Inc. has the following assets:

Only the gain attributable to the investment of working capital in Marketable Securities will be subject to the additional 3.8% Net Investment Income Tax.  The remainder of the gain is not subject to the Net Investment Income tax because A and B are active participants in the business and the assets are used in the ordinary course of that business.  Therefore A and B will each have a capital gain of $50,000, and $12,500 ($25,000 total) of that will be subject to the additional 3.8% Net Investment Income Tax.

As a further example, A owns 50% of the stock of AB Inc, an S Corporation.  A sells his stock for $200,000 and has an adjusted basis in his stock of $120,000.  Therefore, A has a capital gain of $80,000.

AB Inc. has the following assets used in the following business activities:

A will be subject to the additional net investment income tax on the net gain from the assets used in activities X and Y because he was not a material participant in activities X and Y.  In addition, A will be subject to the net investment income tax on the net gain in marketable securities because these assets are not used in the ordinary course of the trade or business.

Therefore of A’s $80,000 total gain, $20,000 of such gain will be subject to the additional 3.8% tax on Net Investment Income.  (20,000) loss from X + 32,000 gain from Y + 8,000 gain from marketable securities = $20,000 total gain subject to Net Investment Income Tax (Medicare Tax).

Car 754 (Election), Where Are You?
The IRS Approves a Late-Filed 754 Election in PLR 201638009
by Christopher Denicolo

An entity taxed as a partnership for federal income tax purposes is often well-served in making a Section 754 Election or having such an election in place where a partnership interest is sold or exchanged, or a partner dies to receive a positive basis adjustment on its appreciated assets. This 754 Election allows for a basis adjustment under Internal Revenue Code Section 743(b) on the assets held under the partnership, and will result in an increase or decrease of the adjusted basis of the partnership assets based upon what a transferee partner pays for a partnership interest (in the event that a partnership interest is sold or exchanged), or based upon the a fair market value of a deceased partner’s interest in the partnership. This basis adjustment is in addition to the adjustment to a transferee partner’s or a deceased partner’s “outside” basis in his or her partnership interests that occurs independent of whether a Section 754 Election is in place.

Under the Treasury Regulations, a 754 Election must be made in a written statement filed with the partnership tax return for the taxable year during which the transfer occurs or the deceased partner dies. In order for the election to be valid, the return must be filed no later than the due date for the partnership’s tax returns, including extensions. However, Treasury Regulation Sections 301.9100-1 through 301.9100-3 provide that the IRS may grant a reasonable extension of time to make a 754 Election (among other elections).

Specifically, Section 301.9100-3 provides that the IRS will grant an extension when a taxpayer provides evidence to establish to the IRS’ satisfaction that the taxpayer acted reasonably and in good faith, and that the grant of the relief sought will not prejudice the interest of the government. The IRS has been somewhat reluctant to grant relief under this Section unless the taxpayer has considerable evidence to show that they acted reasonably and in good faith, and that detriment to the government will not occur based upon such late-filed election being granted.

In Private Letter Ruling 201638009, the IRS granted an additional 120 days from the date of release of this PLR for the taxpayer to make a 754 Election in the taxable year in which one of its partners passed away. The PLR indicates that the taxpayer claimed that its tax advisors did not advise the taxpayer of the opportunity to make a 754 Election and did not make the election while preparing the relevant tax returns. The taxpayer quite likely provided affidavits from the tax advisors to confirm this.

This Ruling provides hope to those taxpayers who may have missed the 754 Election window because they were not informed of it by their tax advisors, or for other bona fide reasons beyond their control. Nevertheless, the Ruling stresses the importance that tax advisors confirm whether a 754 Election is in place, or to remind their clients of the opportunity to file a 754 Election when a partnership interest is transferred or a partner dies in order to create a possibly advantageous tax situation for the partnership.

Partnerships with appreciated assets should undoubtedly assure that a 754 Election is in effect for the tax year when a partnership interest is transferred or a partner dies. Tax advisors who do not inform their clients of this opportunity risk malpractice and face the anxiety of the IRS not being as lenient in granting relief as it was in PLR 201638001.

Missing the 754 Election window could cause the partners of the partnership to incur greater amounts of income tax on the eventual sale of the property, and loss of possible depreciation deductions. It is an easy and high-impact item for advisors to recommend, but also an easy item to miss. Hopefully, this PLR will sound the siren for tax advisors of the importance of reminding their clients that a 754 Election is available, and can provide advantageous results.

Health and Information Technology
by Pariksith Singh, M.D.

Pariksith Singh, M.D. is a board-certified internal medicine physician who received his medical education at Sawai Man Singh Medical College in Rajasthan, India (where he was awarded honors in internal medicine and physiology). His residency training occurred at All India Institute of Medical Services (New Delhi, India) and Mount Sinai Elmhurst Services, (Elmhurst, New York). Upon completion of his residency, Dr. Singh relocated to Florida and worked for several years before establishing Access Health Care, LLC in 2001.

“East is East and West is West, and never the twain shall meet,” sang Rudyard Kipling. The same, perhaps, goes for health care and information technology. The two fields are so far apart, and seemingly in conflict, that we see the glaring lack of digitization in health care even today. Having observed this conflict in my own organization, I have worked to determine why this is so.

It is perhaps the difference in training and approach that defines each discipline. While practicing medicine involves the personal touch and is dependent on relationship management and good communications, developing great software programs is more a result of comprehensive planning, figuring out the end-result and stories right at the beginning, and relationships with numbers rather than people.

We see how this glaring gap brings out serious differences in perception and approach, an understanding of which might be critical to recognize the uniqueness of each specialty and give us the ability to bring them together.

How can we digitize health care? We see physicians frustrated by the inhumaneness of computers, the sluggishness of entering patient information into the electronic medical records, and the divide it can create between the provider and the patient in the exam room. There seems to be a veil created between the healer and the healing. The intuitive approach and heuristics is lost. The ability to understand the patient’s reality is lost, and the response to a complex array of data, which is often dependent on a careful listening, is seriously compromised.

At the very inception, let us recognize the difference in the two gestalts. When a healer enters the exam room, he sees a human, perhaps a friend, someone with whom there is sympathy or empathy. The connection and sharing of information is intimate and discreet. With the new requirements of entering HCC (Hierarchical Condition Categories) codes and HEDIS (Healthcare Effectiveness Data and Information Set) interventions into the computer weighing heavily on each provider, this close engagement is torn by demands of regulatory, institutional, and legal requirements. No matter how good the workflows of the electronic medical record system in use, the job of a provider is seldom easier. The support of the IT infrastructure is minimal, and the time and effort wasted at critical moments of communication can be extremely detrimental.

The approach of a software developer is architectural. He or she needs to see the full picture before the work will begin. The plan has to be in place, the drawings or stories recorded, and the complete set of plans agreed to mutually. Only then does the implementation begin. The approach of a physician is more like writing a lyric. He or she feels, responds, sings, writes, and his work is often done in brief spurts.

The approach of a software developer is like building an ancient temple of South India or a cathedral while that of a provider is a Picasso-like immediate response, although there is years of training, education, and experience behind that response. The healer needs to listen, emote, feel, touch, and connect. The software builder has to detach, objectivize, calculate, and program with mathematical precision. The quality controls of a provider are patient satisfaction, better outcomes, compassion, and sensitivity. The quality controls of a software designer are algorithms, classification, clustering, nomenclature and iteration.

Theirs is the gap between instinct and reason, the subliminal and the rational, rules of thumb and rules of algorithm, a lived and a planned existence, and yet, this distance, too, can be abridged. The following might be helpful tools:

1.) 10, 000 hours of intense and close engagement – It is by spending time with each other, in continuous dialog that is open-ended and in a positive atmosphere, that can bridge and leverage differences.

2.) Shared goals – a clear enunciation of goals, as far as possible if in over-arching vision, if not in details, helps both sides come together. The more distant and transcendental it is, the better.

3.) Cross learning – Teaching each other about one’s specialty and subject matter expertise is of crucial importance for bulwarking and synergizing as a team.

4.) Partnership with a win-win model – The models of future corporations are more and more collaborative and not confrontational, cooperative, or competitive. If this can be understood deeply, the metamorphosis is easy.

5.) Integration of operations and technology – Technology by itself is seldom the solution. A relentless focus on details and minutiae of work flow grounds it and reduces abstract and complexity in developing solutions.

6.) Cognizance of each other’s uniqueness – This will happen organically as communications improve.

7.) Leaning by doing: Iteration is the approach to take in operations and software development. This can’t be iterated often enough.

8.) Healthy respect for each other and conflict resolution mechanism – Problems and miscommunication will happen. The key is in the approach. If the team members are capable of sitting together and resolving the disharmony, no matter how contentious, the future is secure.

9.) Leadership on both sides – The teams will rise to the highest level of the leader’s capacities, to paraphrase the Peter Principle. Immense fortitude and forbearance is needed on both sides to go beyond minor and petty conflicts.

10.) Focusing on the patients and providers – This is perhaps the most critical element of all. As long as the patient and providers are kept in mind, all shall be done. A relentless reminding of this is the sine qua non, the essential condition.

If these differences can be taken advantage of, new solutions are possible. Indeed, with the crosspollination of ideas among vastly different disciplines, innovation can be actualized.

Richard Connolly’s World
Caring for Pets As Part of Your Estate Plan

Insurance advisor Richard Connolly of Ward & Connolly in Columbus, Ohio often shares pertinent articles found in well-known publications such as The Wall Street Journal, Barron’s, and The New York Times. Each week, we will feature some of Richard’s recommendations with links to the articles.

This week, the article of interest is “Caring for Pets As Part of Your Estate Plan” by Catherine F. Schott Murray. This article was published on The National Law Review on April 21, 2016.

Richard’s description is as follows:

Many, if not all, of us have had a pet during our lifetimes. But what happens to that pet if the owners becomes incapacitated or dies? Virginia (Section 64.2-726), Maryland (Section 14.5-407), and the District of Columbia (Section 19-1304.08) all have statutes that permit the creation of a trust for the care of a pet.

In determining how to provide for a pet during incapacity and/or at death, there are a few important items to remember. This article provides a good checklist for clients worried about their pets and for the advisors that help them.

Please click here for a comprehensive checklist and to read this article in its entirety.

Thoughtful Corner
The Vast Majority of Professionals Act Like Professionals

The Thursday Report is very reluctant to comment on political races, although we did support Abraham Lincoln when he ran against John C. Breckinridge, John Bell, and Stephen A. Douglas in 1860. We also supported Franklin D. Roosevelt when he ran against Herbert Hoover. The Thursday Report, however, does always salute professionalism, proper etiquette and manners, and helping others to do their very best.

With that in mind, and having saluted Gerald Ford in the last edition of The Thursday Report, we today salute another consummate gentleman in American history, Jimmy Carter, the 39^th President of the United States who lost by a landslide in an election against Ronald Reagan in 1980.

Jimmy Carter was never accused of saying bad things about any specific interest group or gender, using the wrong email server, or making significant money from his position as a President, ex-President, or developer of thousands of houses in helping to pioneer Habitat for Humanity (yes, he and Rosalynn Carter were a part of that!)

The Jimmy Carter Presidential Museum in Atlanta, George is an extremely interesting and informative museum, which points out that even a nuclear submarine engineer and peanut farmer from modest beginnings (and with the support of the Allman Brothers, who played benefits for Jimmy Carter in 1976) can be President and can be extremely well-respected for decades thereafter.

Our favorite Jimmy Carter video on YouTube is from 2015, where, at age 90, he announced that he had brain cancer and would be receiving treatment. He brought prepared notes to the table where he sat and spoke, but he did not even look at them during an extremely interesting and eloquent 38-minute talk in which he also discusses foreign policy, his confidence in our system, and his resolve to follow doctors’ instructions and see what happens. You can view this video by clicking here.

Knowing that people like Jimmy Carter and Gerald Ford will always be out there to help in rising our political system is a great example of a reason to contribute to our political system and something to be proud of.

The Thursday Report welcomes questions, comments, and suggestions of all kinds and closes this Thoughtful Corner with the following quote from Abraham Lincoln:

“Every man is said to have his peculiar ambition. Whether it be true or not, I can say, for one, that I have no other so great as that of being truly esteemed of my fellow men by rendering myself worthy of their esteem. How far I shall succeed in gratifying this ambition is yet to be developed.”

Humor! (Or Lack Thereof!)

Sign Saying of the Week

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IN THE NEWS
by Ron Ross

Good news for manufacturing!

Donald Trump throws Mike Pence under the bus. Paul Ryan throws Donald Trump under the bus. The DNC throws Bernie Sanders under the bus. Bill Clinton throws Obama under the bus. WikiLeaks throws Hillary Clinton under the bus.

America has run out of busses! It’s mostly damage to the suspension, but Greyhound has ordered thousands of new vehicles rather than repairing the old ones.

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If you’ve tried to email Alan Gassman this week, you may
have received the following away message:

I’m in Garrison New York,
At a retreat to embark,
On new things and old,
Like getting penicillin from mold.

Although I’m away,
Our great team had to stay,
And is glad to help,
Just call, e-mail or yelp.

After hours in Garrison,
There will be no comparison,
But I may check in for matters,
Between pidders and padders,

Thanks so much
For understanding my hunch,
That a time away for thought,
Enhances the good and helps reduce the naught.

Have a great day, and in all reality,
We’ll respond this week, with grace and hospitality.
And so lucky the hurricanes have missed us again,
It is always quite good to have luck as a friend.

Upcoming Seminars and Webinars

Calendar of Events

LIVE COMPLIMENTARY WEBINAR:

Sandra Greenblatt and Alan Gassman will present a free, 30-minute webinar on the topic of AVOIDING THE TRAPS IN EMR/TECHNOLOGY CONTRACTS.

There will be two opportunities to attend this presentation.

Date: Thursday, October 20, 2016 | 12:30 PM or 5:00 PM

Location: Online webinar

Additional Information: To register for the 12:30 PM presentation, please click here. To register for the 5:00 PM presentation, please click here. For more information, please contact Alan Gassman at agassman@gassmanpa.com.

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LIVE COMPLIMENTARY WEBINAR:

Sean Healy and Alan Gassman will present a free, 30-minute webinar on the topic of GUN TRUST UPDATE – NEW RULES AND REGULATIONS YOU NEED TO KNOW ABOUT.

Sean Healy currently operates Healy Law Offices, P.C. in Tyler, Texas, where he has been practicing law for over 20 years. He represents a number of business and nonprofit organizations and focuses on litigation, including jury trials and various types of court cases, including family law cases of divorce, child custody, and others. He is a Life Member of the National Rifle Association and the Texas State Rifle Association and has competed in over 150 pistol competitions.

The second edition of The Legal Guide to NFA Firearms and Gun Trusts by Sean Healy, Jonathan Blattmachr, Alan Gassman, and others will soon be available at the Amazon web store in your neighborhood. We aim to please!

There will be two opportunities to attend this presentation.

Date: Tuesday, October 25, 2016 | 12:30 PM or 5:00 PM

Location: Online webinar

Additional Information: To register for the 12:30 PM presentation, please click here. To register for the 5:00 PM presentation, please click here. For more information, please contact Alan Gassman at agassman@gassmanpa.com.

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LIVE SARASOTA PRESENTATION:

Alan Gassman will present a talk at the 2016 Mote Vascular Symposium on the topic of ESTATE, MEDICAL PRACTICE, RETIREMENT, TAX INSURANCE, AND BUY/SELL PLANNING: THE EARLIER YOU START, THE SOONER YOU WILL BE SECURE.

Date: Saturday, October 29, 2016 | Alan speaks at 3:20 PM

Location: The Hyatt Regency Sarasota | 1000 Boulevard of the Arts, Sarasota, FL, 34236

Additional Information: If you are interested in registering for this presentation, please email Stephanie at stephanie@gassmanpa.com. For more information, please contact Alan Gassman at agassman@gassmanpa.com.

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LIVE COMPLIMENTARY BLOOMBERG BNA WEBINAR:

Sanford J. Schlesinger will be presenting a free, Bloomberg BNA Essential Elements webinar entitled “2016 Developments You Need to Know About.” This presentation will be moderated by Alan S. Gassman.

Date: Thursday, November 10, 2016

Location: Online webinar

Additional Information: If you are interested in registering for this presentation, please email Stephanie at stephanie@gassmanpa.com. For more information, please contact Alan Gassman at agassman@gassmanpa.com.

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LIVE BLOOMBERG BNA WEBINAR:

Howard Fisher, Denis Kleinfeld, and Alan Gassman will be presenting a Bloomberg BNA Practical & Creative Planning webinar entitled “2016 Developments You Need to Know About.”

Date: Tuesday, November 15, 2016

Location: Online webinar

Additional Information: If you are interested in registering for this presentation, please email Stephanie at stephanie@gassmanpa.com. For more information, please contact Alan Gassman at agassman@gassmanpa.com.

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LIVE MAUI PRESENTATION:

2016 MAUI MASTERMIND WEALTH SUMMIT

Alan Gassman will be speaking at the 2016 Maui Mastermind Wealth Summit with David Finkel and others. This event will connect attendees with many Maui Mastermind Wealth Advisors such as Alan.

During this week-long event, Alan will be speaking on the following topics:

• Getting Out of Bad Financial Partnerships, Joint Ventures, or Strategic Relationships
• Asset Protection and Estate Planning for Business Owners
• The Estate Planning and Asset Protecting “Choose Your Own Ending” Game
• The Language of Investing
• Engineering a Better Investment Deal

Thursday Report attendees will receive a free Mai-Tai with call brand liquor and their choice of a hula hoop or Hawaiian lei. Watch Don Juan sing the greatest hits of Conway Twitty on December 7^th at 7:00 PM Hawaiian Time.

Date: December 4^th – December 9^th, 2016

Location: The Fairmont Kea Lani Maui | 4100 Wailea Alanui Drive, Maui, HI, 96753

Additional Information: For more information, please email Alan Gassman at agassman@gassmanpa.com.

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LIVE TAMPA PRESENTATION:

ANNUAL ALEXANDER L. PASKAY MEMORIAL BANKRUPTCY SEMINAR

Alan Gassman will speak on a panel discussion at the American Bankruptcy Institute’s annual Alexander L. Paskay Memorial Bankruptcy Seminar on the topic of THE ETHICS OF ASSET PROTECTION.

Date: Thursday, February 2, 2017 | Time TBD

Location: The Embassy Suites Tampa Downtown Convention Center | 513 S. Florida Avenue, Tampa, FL, 33602

Additional Information: If you are interested in registering for this presentation, please email Stephanie at stephanie@gassmanpa.com. For more information, please contact Alan Gassman at agassman@gassmanpa.com.

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LIVE ORLANDO PRESENTATION:

REPRESENTING THE PHYSICIAN: IT IS HARDER THAN IT LOOKS

Alan Gassman will present two talks at the 2017 Annual Florida Bar Health Law and Tax Section Representing the Physician Seminar. His topics include:

• A Brief Introduction to Representing the Physician (with Lester J. Perling)
• Structuring Medical Practices and Related Entities for Tax, Creditor Insulation, and Regulatory Compliance Purposes (with Lester J. Perling)

Other speakers at this event include William Eck, Susan Thomas, Melissa Mora, Sachi Mankodi, Kimberly Brandt, Al Gomez, Kathleen Premo, and Radha Bachman.

Other topics at this event include:

• The Brave New World of Medicare Physician Compensation Under MACRA and Beyond
• Office of Civil Rights HIPAA Audits – Preparing Your Clients and Yourself
• The Physician’s Role Under EMTALA and the Florida Access to Emergency Services Act
• Medical Marijuana in Florida – The Highs and Lows of its Regulation
• The Post-Election View from the Hill
• What the Doctor’s Lawyer and the Doctor Need to Know About Bankruptcy and How Creditors Approach Health Industry Related Situations
• Medicare and Other Risk Contracts
• Medical Entities and Rules You Must Know About

To download the complete schedule, please click here.

Date: Friday, February 3, 2017 | Alan speaks at 8:30 AM and 4:10 PM.

Location: Rosen Centre Hotel | 9840 International Drive, Orlando, FL, 32819

Additional Information: If you are interested in registering for this presentation, please email Stephanie at stephanie@gassmanpa.com. For more information, please contact Alan Gassman at agassman@gassmanpa.com.

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LIVE STETSON LAW SCHOOL PRESENTATION:

Saturday, February 11, 2017
Professional Achievement Workshop with Dr. Srikumar Rao and Alan Gassman

Join Dr. Rao and Alan Gassman for a 6-hour interactive, very interesting workshop to enable recent law school graduates and others to reach new levels of enjoyment and achievement in your business or professions.

This is based on Alan’s workshop materials that have been presented on many occasions at the University of Florida, Ave Maria School of Law, State and City Bar conferences, and elsewhere. This workshop will be free of charge for law and MBA students; a donation will be determined for all other interested participants. This workshop includes free course materials and a subscription to The Thursday Report.

Sunday, February 12, 2017
Srikumar Rao’s Guide to Eliminating Stress and Anxiety for Professionals and Others

This 6-hour workshop will be a private event held by the Rao Institute at the request of Alan Gassman and friends. This will be provided for a limited number of attendees as a cost of $475 per person. Please RSVP now while spaces are available!

See Dr. Rao’s YouTube TED Talk, and you will see why he is so well-regarded and sought out worldwide as a presenter, coach, and author. Meet this gentle and brilliant man who has changed so many lives up close and personal!

You can see his best-selling books, Are You Ready to Succeed? and Happiness at Work on Amazon by clicking here. You can also see his TED Talk that has been viewed by well-over 1 million people by clicking here.

EMAIL AGASSMAN@GASSMANPA.COM TO RSVP TO EITHER EVENT.

Date: Saturday, February 11, 2017 and Sunday, February 12, 2017

Location: Stetson Law School, Gulfport Campus | 1401 61^st Street South, St. Petersburg, FL, 33707

Additional Information: For more information, please email Alan Gassman at agassman@gassmanpa.com.

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LIVE DISNEY WORLD PRESENTATION (HOW MICKEY MOUSE CAN YOU GET?):

2017 MER CONTINUING EDUCATION PROGRAM TALKS FOR PHYSICIANS

Alan Gassman will be speaking at the Medical Education Resources (MER) Internal Medicine and Country Bear Jamboree for primary care physicians and other characters. We thank MER for this wonderful opportunity and Walt Disney for having paved all of Osceola County. His topics will include:

• The 10 Biggest Mistakes Physicians Make in Their Investments and Business Planning
• Lawsuits 101
• 50 Ways to Leave Your Overhead
• Essential Creditor Protection and Retirement Planning Considerations

Date: Wednesday, March 15, 2017 and Thursday, March 16, 2017

Location: Walt Disney World BoardWalk Inn | 2101 Epcot Resorts Blvd, Kissimmee, FL 34747

Additional Information: For more information, please email Alan Gassman at agassman@gassmanpa.com.

Save the Dates!

LIVE SOUTH BEND, INDIANA PRESENTATION:

42^ND ANNUAL NOTRE DAME TAX & ESTATE PLANNING INSTITUTE

Please put Thursday, October 27^th and Friday, October 28^th on your calendars for the 42^nd Annual Notre Dame Tax & Estate Planning Institute. To see the complete schedule and for registration details, please click here.

A key attraction of this year’s conference is that Alan Gassman will not be speaking! There will, therefore, be limited seating available, so register now.

Date: Thursday, October 27^th, 2016 and Friday, October 28^th, 2016

Location: Century Center | 120 South Saint Joseph Street, South Bend, IN, 46601

Additional Information: For more information, please email Alan Gassman at agassman@gassmanpa.com.

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LIVE ST. PETERSBURG PRESENTATION:

2017 ALL CHILDREN’S HOSPITAL FOUNDATION SEMINAR

Please put Thursday, February 9^th, 2017 and on your calendar to enjoy the 19^th Annual All Children’s Hospital Estate, Tax, Legal, and Financial Planning Seminar.

Speakers will include Turney Berry, Paul Lee, Sanford Schlesinger, and Jerry Hesch.

Date: Thursday, February 9^th, 2017

Location: Johns Hopkins All Children’s Hospital Education and Conference Center, St. Petersburg, FL

Additional Information: For more information, please email Alan Gassman at agassman@gassmanpa.com.

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LIVE NAPLES PRESENTATION:

4^th ANNUAL AVE MARIA SCHOOL OF LAW ESTATE PLANNING CONFERENCE

Please put Friday, April 28^th, 2017 and the weekend that follows on your calendar to enjoy the 4^th Annual Ave Maria School of Law Estate Planning Conference and the weekend that follows in Naples with the person or persons of your choice.

Alan Gassman will be speaking at this conference on the topic of THE ETHICS OF AVOIDING TRUSTS AND ESTATE LITIGATION.

Date: Friday, April 28^th, 2017

Location: The Ritz-Carlton Golf Resort | 2600 Tiburon Drive, Naples, FL, 34109

Additional Information: For more information, please email Alan Gassman at agassman@gassmanpa.com.

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LIVE LAS VEGAS PRESENTATION:

AICPA ADVANCED PERSONAL FINANCIAL PLANNING CONFERENCE

Alan Gassman will be speaking at the Advanced Personal Financial Planning Conference, sponsored by The American Institute of CPAs. His tentative topic for this event is LIFE INSURANCE TIPS FOR THE FINANCIAL PLANNING PROFESSIONAL.

This conference is part of the AICPA ENGAGE event, which brings together five well-known AICPA conferences with the Association for Accounting Marketing Summit for one, four-day event. The conferences included in ENGAGE are Advanced Personal Financial Planning, Advanced Estate Planning, Tax Strategies for the High-Income Individual, the Practitioners Symposium/TECH+ Conference, the National Advanced Accounting and Auditing Technical Symposium, and the Association for Accounting Marketing Summit.

Date: June 12^th – June 15^th, 2017 | Alan’s date and time are to be determined.

Location: MGM Grand | 3799 S. Las Vegas Blvd., Las Vegas, NV, 89109

Additional Information: For more information, please email Alan Gassman at agassman@gassmanpa.com or click here.

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LIVE PRESENTATIONS:

2017 MER CONTINUING EDUCATION PROGRAM TALKS FOR PHYSICIANS

Alan Gassman will be speaking at the following Medical Education Resources (MER) events:

• October 20^th – October 22^nd, 2017 in New York, New York
• November 30^th – December 3^rd, 2017 in Nassau, Bahamas

His tentative topics for these events include the 10 Biggest Mistakes Physicians Make in Their Investments and Business Planning, Lawsuits 101, 50 Ways to Leave Your Overhead, and Essential Creditor Protection and Retirement Planning Considerations.

Date:
New York: Friday, October 20th, 2017 – Sunday, October 22nd, 2017
Bahamas: Thursday, November 30th, 2017 – Sunday, December 3rd, 2017

Location:
New York: To be determined.
Nassau: Atlantis Hotel | Paradise Beach Drive, Paradise Island, Bahamas

Additional Information: For more information, please email Alan Gassman at agassman@gassmanpa.com.

Applicable Federal Rates

Below we have this month, last month’s, and the preceding month’s Applicable Federal Rates, because for a sale you can use the lowest of the 3.