"This document may not be used or cited as precedent. Section 6110(j)(3) of the Internal Revenue Code."

Size: px
Start display at page:

Download ""This document may not be used or cited as precedent. Section 6110(j)(3) of the Internal Revenue Code.""

Transcription

1 PRIVATE RULING "This document may not be used or cited as precedent. Section 6110(j)(3) of the Internal Revenue Code." Dear * * * This is in reply to a letter dated October 30, 1990, and subsequent correspondence, in which a ruling is requested on behalf of Association that the money it receives under a settlement agreement, and interest earned on accounts funded with the settlement payments, be considered excludible from the gross income of the Association. FACTS You have represented that Association qualifies as a homeowners association under section 528 of the Internal Revenue Code. Association was incorporated under the laws of state P for the purpose of preserving and maintaining the common areas of the property owned by the unit owners, who also own and control Association. On a, Association filed suit on behalf of the unit owners against M, the developer of the property that Association was formed to maintain. The suit alleged various construction defects to common areas of the property as well as M's failure to establish adequate cash reserves to repair and/or replace the defective property. Association sought to recover an amount sufficient to repair or replace the defective common area property. In b, Association reached a settlement with M on behalf of the unit owners. The settlement agreement provides for the following payments: "1) an initial lump sum payment of x dollars from M to Association; 2) a payment of approximately y dollars from M to N, an insurance company, to establish an annuity (discussed below); and 3) annual and periodic annuity payments from N to Association." Association intends to place the lump sum payment of x dollars in a physically segregated, interest bearing account. The payment, together with the interest earned thereon, will be used to repair and replace the defective property over time as such repairs and replacements become necessary. The annuity will be owned exclusively by N. On and after the annuity commencement date, O, a second insurance company, will pay annual annuity payments to Association at an annual annuity rate of z dollars. The annuity

2 contract also provides that O will make three additional payments to Association on dates specified in the contract. As with the lump sum payment, Association will place amounts received under the annuity contract in physically segregated, interest bearing accounts. The payments, and interest earned thereon, will be used to repair and replace defective property over time. The total amount Association is to receive in initial lump sum and annuity payments is the settlement parties' estimation of the present value of the damages Association is likely to incur over time from the construction defects. The parties arrived at this figure after consulting with several engineering firms to evaluate the defects. You have represented that Association has acted at all times for and on behalf of the unit owners, and that all funds are to be held for their benefit. The unit owners, however, will not have the right to receive or withdraw any payments received, any amounts deposited, or any interest earned. All funds will remain the property of Association until expended for the repair or replacement of the common areas. LAW AND ANALYSIS Section 61(a) of the Code provides that, except as otherwise provided, gross income means all income from whatever source derived. Under section 61(a)(4), interest is an item includible in gross income. Similarly, under section 61(a)(9), amounts received under an annuity are includible in gross income. Section 528(b) of the Code imposes a tax for each taxable year on the homeowners association taxable income of every homeowners association. Section 528(d)(1) defines "homeowners association taxable income" to be the excess of an association's gross income for the taxable year (excluding exempt function income) over the deductions allowed under section 528(d)(1)(B). Section 528(d)(3) of the Code provides that the term "exempt function income" means any amount received as membership dues, fees, or assessments from owners of condominium housing units in the case of a condominium management association, or owners of real property in the case of a residential real estate management association. Section (c)(4) of the Income Tax Regulations provides as an example of a receipt that is not exempt function income, interest earned on amounts set aside in a sinking fund. The treatment of amounts received as proceeds of a lawsuit or settlement depends upon the nature of the claim and the actual basis for recovery. If the recovery represents damages for lost profits, it is taxable to the recipient as ordinary income. If, however, the recovery is received as replacement of lost capital, it is not taxable. Raytheon Production Corp. v. Commissioner, 144 F.2d

3 110, 113 (1st Cir.), cert. denied, 323 U.S. 779 (1944); Freeman v. Commissioner, 33 T.C. 323, 327 (1959); Rev. Rul , C.B. 14. In Rev. Rul , C.B. 433, the Service considered a case where a homeowner's association instituted an action against the builder of a condominium development on behalf of the unit owners for damages arising from defects in the construction of the condominium development. The revenue ruling holds that the money received from the builder was not income to the association. In Rev. Rul , C.B. 74, the taxpayer sued to recover damages for personal injuries sustained from the conduct of the defendant. Before trial, the parties reached a settlement that obligated the defendant to make a lump sum payment to an insurance company to purchase an annuity that would fund monthly payments to the taxpayer. The insurance company was the owner of the annuity contract and possessed all rights of ownership. The revenue ruling holds that the insurance company's purchase of the annuity contract was merely an investment by the company to provide a source of funds to satisfy the settlement obligation to the taxpayer. Accordingly, both the amount paid for the annuity contract, and the monthly payments to the taxpayer, were excludible from the taxpayer's gross income under section 104(a)(2) of the Code as damages received on account of personal injury or sickness. See also Rev. Rul , C.B. 75. In the instant case, Association negotiated the settlement with M to compensate Association for the cost of correcting construction defects to common areas that Association is obligated to preserve and maintain. The money received by Association, in the form of both a lump sum payment and annual and periodic annuity payments, is intended to compensate Association for capital it will have to use in order to make the necessary repairs and replacements. Association intends to place the lump sum payments and the annual annuity payments in separate interest bearing accounts. The interest earned on the accounts also is to be used to make necessary repairs and replacements. In Rev. Rul , C.B. 59, the Service addressed the question of whether interest realized from the investment of a damage award was excludible from the taxpayer's gross income under section 104(a) of the Code. On the taxpayer's suit for tortious injury to his wife, the Court awarded 416x dollars, which represented the present value of 520x dollars payable over the wife's estimated remaining life expectancy. The latter amount was the taxpayer's estimated reasonable cost of care, medicine, and medical attention for his wife over the same period. The taxpayer had unfettered control of the lump sum payment and the interest earned from investing it. Thus, the revenue ruling holds

4 that the lump sum payment was excludible from income under section 104, but the interest was taxable. See also Rev. Rul , C.B. 74. In the instant case, Association maintains unfettered use of the invested funds and interest. These amounts will be set aside for the Association to draw upon to repair or replace common property. The unit owners have no right to draw on the funds or to receive a credit of any of the interest upon disposition of their units. Thus, the interest earned on the accounts is similar to interest earned on a sinking fund established by an association from an assessment on its unit owners. Accordingly, based on the facts submitted, and on the above law and rationale, we conclude the following: 1) the initial lump sum payment represents damages for lost capital and is not includible in Association's gross income; 2) the payment by M to N to purchase an annuity contract to fund payments to Association is not includible in Association's gross income; 3) the annual and periodic annuity payments represent damages for lost capital and are not includible in Association's gross income; 4) interest earned on investment of the lump sum payment Association receives under the settlement agreement is includible in its gross income. The interest will not be exempt function income for purposes of section 528 of the Code; and 5) interest earned on investment of the annuity payments Association receives under the settlement agreement is includible in its gross income. The interest will not be exempt function income for purposes of section 528 of the Code. We express no opinion as to the federal tax consequences of the transaction described above under any other provision of the Code. We express no opinion on the consequences to the unit owners of amounts received under the settlement agreement, or on whether Association qualifies as a homeowners association under section 528(c) of the Code. In accordance with the power of attorney submitted, we are sending a copy of this ruling to Association. Association should attach a copy of this ruling to its tax return for the taxable year in which the transaction covered by this ruling is consummated. This ruling is directed only to the taxpayer who requested it. Section 6110(j)(3) of the Code provides that it may not be used or cited as precedent.

5 Sincerely yours, Assistant Chief Counsel (Income Tax & Accounting) Peter J. Frederick Assistant to the Chief, Branch 2 Enclosure: Copy for section 6110 purposes TSLG SYNOPSIS: Private Ruling , below, taxes interest earned by an Association on settlement proceeds received as a lump-sum for repairs of construction defects by a developer. PRIVATE RULING "This document may not be used or cited as precedent. Section 6110(j)(3) of the Internal Revenue Code." DATE: July 23, 1990 Dear * * * This is in reply to a letter dated January 30, 1990, in which a ruling is requested that with respect to the Association the interest earned on amounts received in settlement of a pending lawsuit constitutes exempt function income, as defined in section 528(d)(3) of the Internal Revenue Code. The facts and representations are as follows. In a, the Association received a settlement of a pending lawsuit for defective construction. In a, the Association received funds in the amount of c pursuant to the settlement. In b, the Association received funds in the amount of d also pursuant to the settlement. The funds received are earmarked for specific repair items. The funds are held in interest bearing accounts until they are used.

6 The Association has requested a ruling that the interest earned on the funds received in the lawsuit settlement be considered exempt function income, as defined in section 528(d)(3) of the Code. Section 528(a) of the Code generally provides that certain condominium management associations and residential real estate management associations are subject to federal income tax only to the extent provided in section 528(b). Section 528(b) imposes a 30 percent tax on the homeowners association taxable income received in a taxable year by a homeowners association, as defined in section 528()(1). Section 528(d)(1) of the Code defines the term "homeowners association taxable income." Generally, homeowners association taxable income is equal to the excess of the gross income (excluding exempt function income) of the homeowners association over the deducitons directly connected with that gross income (excluding exempt function income). The deductions allowed for purposes of computing homeowners association taxable income are the deductions generally allowed for computing taxable income, as modified by section 528(d)(2). See section of the Income Tax Regulations. The term "exempt function income" is defined by section 528(d)(3) of the Code as any amount received as membership dues, fees, or assessments from (A) owners of condominium housing units in the case of a condominium management association, or (B) owners of real property in the case of a residential real estate management association. Section (9)(a) of the regulations provides, in part, that exempt function income consists solely of income which is attributable to membership dues, fees, or assessments of owners of residential units or residential lots. It is not necessary that the source of income be labeled as membership dues, fees, or assessments. What is important is that such income be derived from owners of residential units or residential lots in their capacity as owner-members rather than in some other capacity such as customers for services. Generally, for the membership dues, fees, or assessments with respect to a residential unit or lot to be exempt function income, the unit must be used for (or the unit or lot must be expected to be used for) residential purposes.... Furthermore, income attributable to dues, fees, or assessments will not be considered exempt function income unless each member's liability for payment arises solely from membership in the association.

7 Section (c) of the regulations provides examples of receipts by homeowners associations that do not constitute exempt function income. These examples include amounts received from persons who are not members of the association and interest earned on amounts set aside in a sinking fund. In this instance, the income in question was interest income received from parties who were not members of Association. Since the income was not attributable to membership dues, fees, or assessments of owners of residential units or residential lots, the income is not exempt function income within the meaning of section 528(d)(3) of the Code. We express no opinion as to whether Association qualified as a homeowners association under section 528(c) of the Code. No opinion is expressed or implied regarding the application of any other provision of the Code or regulations. A copy of this letter should be attached to the income tax return filed by Association for the tax year affected by this ruling. A copy is provided for this purpose. This ruling is directed only to the taxpayer who requested it. Section 6110(j)(3) of the Code provides that it may not be used or cited as precedent. Sincerely yours, Assistant Chief Counsel (Passthroughs and Special Industries) Emil O. Muhs, Jr. Chief, Branch 7

Internal Revenue Service Number: 200439017 Release Date: 9/24/04 0061.28-03, 0061.29-00, 0277.00-00

Internal Revenue Service Number: 200439017 Release Date: 9/24/04 0061.28-03, 0061.29-00, 0277.00-00 Internal Revenue Service Number: 200439017 Release Date: 9/24/04 0061.28-03, 0061.29-00, 0277.00-00 -------------------------- --------------------------------------------- ----------------------------------

More information

Whether the transactions in the following situations are, for federal tax purposes,

Whether the transactions in the following situations are, for federal tax purposes, Part I Section 61.--Gross Income Defined 26 CFR 1.61-6: Gains derived from dealings in property. (Also 82, 1001; 1.82-1, 1.6045-4) Rev. Rul. 2005-74 ISSUE Whether the transactions in the following situations

More information

Internal Revenue Service. Number: 200452027 Release Date: 12/24/2004 Index Number: 61.09-18, 117.02-04, 3121.01-00, 3306.02-00, 3401.

Internal Revenue Service. Number: 200452027 Release Date: 12/24/2004 Index Number: 61.09-18, 117.02-04, 3121.01-00, 3306.02-00, 3401. Internal Revenue Service Number: 200452027 Release Date: 12/24/2004 Index Number: 61.09-18, 117.02-04, 3121.01-00, 3306.02-00, 3401.01-00 --------------------------- -------------------------------- ---------------------

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Number: 200924034 Release Date: 6/12/2009 Index Number: 468B.00-00, 468B.04-01, 468B.07-00, 461.00-00, 162.00-00, 172.00-00, 172.01-00, 172.01-05, 172.06-00 -----------------------

More information

Number: 2001-0044 Release Date: 3/30/2001 UIL Number: 451.14-00 CC:ITA:5:KKoch COR-102626-01

Number: 2001-0044 Release Date: 3/30/2001 UIL Number: 451.14-00 CC:ITA:5:KKoch COR-102626-01 DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE WASHINGTON, D.C. 20224 OFFICE OF CHIEF COUNSEL January 19, 2001 Number: 2001-0044 Release Date: 3/30/2001 UIL Number: 451.14-00 CC:ITA:5:KKoch COR-102626-01

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Number: 200741003 Release Date: 10/12/2007 Index Number: 468B.07-00, 162.00-00, 461.00-00, 461.01-00, 172.01-00, 172.01-05, 172.06-00, 108.01-00, 108.01-01, 108.02-00 -----------------------

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Number: 200925003 Release Date: 6/19/2009 Index Number: 2511.00-00, 2042.00-00, 61.09-38 ------------------------- ------------------------- ---------------------------- Department

More information

Number: 200636085 Release Date: 9/8/2006 Internal Revenue Service. Department of the Treasury Washington, DC 20224. Index Number: 162.

Number: 200636085 Release Date: 9/8/2006 Internal Revenue Service. Department of the Treasury Washington, DC 20224. Index Number: 162. Number: 200636085 Release Date: 9/8/2006 Internal Revenue Service Index Number: 162.04-03 ---------------------------- ------------------------------------------------- ---------------------------- -----------------------

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Number: 201435006 Release Date: 8/29/2014 Index Number: 130.00-00, 130.01-00, 130.02-00 ----------------------------------------------- ---------------------------------------------------

More information

INTERNAL REVENUE SERVICE. Number: 200119039 Release Date: 5/11/2001 UIL Nos. 831.03-00 832.00-00. CC:FIP:4 PLR-119217-00 February 8, 2001.

INTERNAL REVENUE SERVICE. Number: 200119039 Release Date: 5/11/2001 UIL Nos. 831.03-00 832.00-00. CC:FIP:4 PLR-119217-00 February 8, 2001. INTERNAL REVENUE SERVICE Number: 200119039 Release Date: 5/11/2001 UIL Nos. 831.03-00 832.00-00 CC:FIP:4 PLR-119217-00 February 8, 2001 Taxpayer = Parent = Subsidiary = Commercial IC = State = Date A =

More information

September 11th Victim Compensation Fund Payments Are Tax- Free

September 11th Victim Compensation Fund Payments Are Tax- Free September 11th Victim Compensation Fund Payments Are Tax- Free The Service has confirmed that periodic payments from the September 11th Victim Compensation Fund to victims of the terrorist attacks will

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Number: 201429007 Release Date: 7/18/2014 Index Number: 1504.02-00, 832.00-00, 832.06-00 --------------- ------------------------------------------------------------ ------------

More information

Date: February 16, 2001

Date: February 16, 2001 ,QWHUQDO5HYHQXH6HUYLFH Number: 200121031 Release Date: 5/25/2001 Index No.: 104.03-00 Department of the Treasury Washington, DC 20224 Person to Contact: Telephone Number: Refer Reply To: CC:ITA:1 PLR-122136-00

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Number: 200750009 Release Date: 12/14/2007 Index Numbers: 368.04-00, 355.01-00 ---------------------- -------------------------------------------------- --------------------------------------

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Department of the Treasury Number: 200042018 Release Date: 10/20/2000 Index Number: 831.03-00 Washington, DC 20224 Person to Contact: Telephone Number: Refer Reply To: CC:FIP:4-PLR-101794-00

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Number: 201045005 Release Date: 11/12/2010 Index Number: 162.25-05 ----------------------- ------------------------------------------- ----------------------------------- --------------------------------------------------

More information

Internal Revenue Service. Department of the Treasury Washington, DC 20224. Number: 200442011 Release Date: 10/15/2004

Internal Revenue Service. Department of the Treasury Washington, DC 20224. Number: 200442011 Release Date: 10/15/2004 Internal Revenue Service Number: 200442011 Release Date: 10/15/2004 Department of the Treasury Washington, DC 20224 Index Number: 382.12-08, 468B.02-00 ---------------------------------------------- -------------------------------------------

More information

Internal Revenue Service Number: 200702006 Release Date: 1/12/2007 Index Number: 3406.00-00, 6041.03-00, 6041.05-00, 6045.00-00, 6049.

Internal Revenue Service Number: 200702006 Release Date: 1/12/2007 Index Number: 3406.00-00, 6041.03-00, 6041.05-00, 6045.00-00, 6049. Internal Revenue Service Number: 200702006 Release Date: 1/12/2007 Index Number: 3406.00-00, 6041.03-00, 6041.05-00, 6045.00-00, 6049.01-00 -------------------------------- ------------------------------------

More information

Section 2519.--Dispositions of Certain Life Estates.

Section 2519.--Dispositions of Certain Life Estates. Part I Section 2519.--Dispositions of Certain Life Estates. 26 CFR 25.2519-1: Dispositions of certain life estates. (Also sections 2044; 2056; 2511; 2512; 20.2044-1; 20.2056(b)-7; 25.2511-1; 25.2512-8)

More information

Internal Revenue Service Department of the Treasury CC:TEGE:QP2 - PLR-167048-01. Entity E =

Internal Revenue Service Department of the Treasury CC:TEGE:QP2 - PLR-167048-01. Entity E = Internal Revenue Service Department of the Treasury Number: 200301032 Release Date: 01/03/2003 Index No. 106.00-00 457.01-00 403.04-00 457.10-00 Legend Entity E = CC:TEGE:QP2 - September 30, 2002 Dear

More information

Index No.: 355.01-00, 643.00-00, 661.0-00 Number:199923044 Release Date: 6/11/1999. In re: LEGEND: Distributing = Trust = Settlor = Child 1 =

Index No.: 355.01-00, 643.00-00, 661.0-00 Number:199923044 Release Date: 6/11/1999. In re: LEGEND: Distributing = Trust = Settlor = Child 1 = Internal Revenue Service Index No.: 355.01-00, 643.00-00, 661.0-00 Number:199923044 Release Date: 6/11/1999 Department of the Treasury P.O. Box 7604 Ben Franklin Station Washington, DC 20044 Person to

More information

Section 72. Annuities; certain proceeds of endowment and life insurance contracts (Also 1001, 1011, 1012, 1221, and 1234A)

Section 72. Annuities; certain proceeds of endowment and life insurance contracts (Also 1001, 1011, 1012, 1221, and 1234A) Part I Section 72. Annuities; certain proceeds of endowment and life insurance contracts (Also 1001, 1011, 1012, 1221, and 1234A) Rev. Rul. 2009-13 ISSUE What is the amount and character of A s income

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Department of the Treasury Number: 200327029 Release Date: 7/3/2003 Index Number: 1362.02-03 Washington, DC 20224 Person to Contact: Telephone Number: Refer Reply To: CC:PSI:2

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Number: 201419007 Release Date: 5/9/2014 Index Number: 831.03-00 ------------------------------------ ------------------------------------- -------------------------------- -------------------------------

More information

Does the arrangement described below constitute insurance within the meaning

Does the arrangement described below constitute insurance within the meaning Part I Section 801. Tax Imposed Rev. Rul. 2014-15 ISSUE Does the arrangement described below constitute insurance within the meaning of subchapter L of the Internal Revenue Code? If so, does the issuer

More information

If the owner-annuitant of a deferred annuity contract dies before the annuity

If the owner-annuitant of a deferred annuity contract dies before the annuity Part I Section 691. Recipients of Income in Respect of Decedents 26 CFR 1.691(a)-1: Income in respect of a decedent. (Also 72, 1014.) Rev. Rul. 2005-30 ISSUE If the owner-annuitant of a deferred annuity

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Index Number: 72.01-00, 72.07-01, 72.17-00, 72.21-00 Number: 200036021 Release Date: 9/8/2000 Department of the Treasury Washington, DC 20224 Person to Contact: Telephone Number:

More information

Rev. Rul. 2002-91, 2002-52 I.R.B. 991 (12/30/2002)

Rev. Rul. 2002-91, 2002-52 I.R.B. 991 (12/30/2002) Rev. Rul. 2002-91, 2002-52 I.R.B. 991 (12/30/2002) Part I Section 831. Tax on Insurance Companies other than Life Insurance Companies 26 CFR 1.831-3: Tax on insurance companies (other than life or mutual),

More information

T.C. Memo. 2010-254 UNITED STATES TAX COURT. THOMAS M. AND DONNA GENTILE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

T.C. Memo. 2010-254 UNITED STATES TAX COURT. THOMAS M. AND DONNA GENTILE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent T.C. Memo. 2010-254 UNITED STATES TAX COURT THOMAS M. AND DONNA GENTILE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 14226-08. Filed November 18, 2010. R determined a deficiency

More information

Internal Revenue Service Number: 200422052 Release Date: 5/28/04 Index Number: 0561.05-00, 0562.03-02, 0851.00-00, 0852.01-00

Internal Revenue Service Number: 200422052 Release Date: 5/28/04 Index Number: 0561.05-00, 0562.03-02, 0851.00-00, 0852.01-00 Internal Revenue Service Number: 200422052 Release Date: 5/28/04 Index Number: 0561.05-00, 0562.03-02, 0851.00-00, 0852.01-00 ------------------------------ ----------------------------- ----------------------

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Department of the Treasury Number: 200203045 Release Date: 1/18/2002 Index Number: 2501.00-00, 2501.01-00, 2036.00-00, 2044.00-00 Re: Washington, DC 20224 Person to Contact: Telephone

More information

CC:DOM:FI&P:4/PLR-113280-98 October 27, 1998

CC:DOM:FI&P:4/PLR-113280-98 October 27, 1998 INTERNAL REVENUE SERVICE UIL Nos. 831.03-00 832.00-00 Number: 199903024 Release Date: 1/22/1999 Parent = CC:DOM:FI&P:4/PLR-113280-98 October 27, 1998 S-1 = S-2 = A = Date B = State C = State D = State

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Number: 201208021 Release Date: 2/24/2012 Index Number: 7704.03-00 --------------------------------------------------- ------------------------------- -----------------------------

More information

This Chief Counsel Advice responds to your request for assistance. This advice may not be used or cited as precedent.

This Chief Counsel Advice responds to your request for assistance. This advice may not be used or cited as precedent. Office of Chief Counsel Internal Revenue Service memorandum Number: 201147024 Release Date: 11/25/2011 CC:ITA:5 POSTF-115572-11 UILC: 61.49-01, 263.00-00, 1001.00-00, 1012.00-00, 1221.00-00, 1222.00-00

More information

INCOME TAX ADVANTAGES OF STRUCTURING ATTORNEY FEES IN THIRD PARTY LIABILITY AND WORKER S COMPENSATION SETTLEMENTS

INCOME TAX ADVANTAGES OF STRUCTURING ATTORNEY FEES IN THIRD PARTY LIABILITY AND WORKER S COMPENSATION SETTLEMENTS INCOME TAX ADVANTAGES OF STRUCTURING ATTORNEY FEES IN THIRD PARTY LIABILITY AND WORKER S COMPENSATION SETTLEMENTS By John J. Campbell, Esq. Introduction The use of structured settlements to settle third

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Number: 201027015 Release Date: 7/9/2010 Index Number: 170.01-00 ------------------------------------------------------------ -------- --------------------------- ---------------------------------------

More information

Section 831.--Tax on Insurance Companies other than Life Insurance Companies

Section 831.--Tax on Insurance Companies other than Life Insurance Companies Part I Section 831.--Tax on Insurance Companies other than Life Insurance Companies (Also 162; 1.162-1.) Rev. Rul. 2005-40 ISSUE Do the arrangements described below constitute insurance for federal income

More information

26 CFR 1.121-1: Exclusion of gain from sale or exchange of a principal residence. (Also: 61, 165, 691, 1001; 1.61-6, 1.165-1, 1.691(a)-1, 1.1001-1.

26 CFR 1.121-1: Exclusion of gain from sale or exchange of a principal residence. (Also: 61, 165, 691, 1001; 1.61-6, 1.165-1, 1.691(a)-1, 1.1001-1. Section 121. Exclusion of gain from sale of principal residence 26 CFR 1.121-1: Exclusion of gain from sale or exchange of a principal residence. (Also: 61, 165, 691, 1001; 1.61-6, 1.165-1, 1.691(a)-1,

More information

Qualified Settlement Funds: A Quick Guide for Trial Lawyers

Qualified Settlement Funds: A Quick Guide for Trial Lawyers Qualified Settlement Funds: A Quick Guide for Trial Lawyers By Jason D. Lazarus, Esq. Introduction Assume you just settled a personal injury case for John Doe who is married to Jane. John has a significant

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Number: 201114015 Release Date: 4/8/2011 Index Number: 832.15-00, 162.04-02, 162.04-03, 263.00-00 ------------------------------- -------------------------------------------------------------

More information

New York State Department of Taxation and Finance Taxpayer Services Division Technical Services Bureau

New York State Department of Taxation and Finance Taxpayer Services Division Technical Services Bureau New York State Department of Taxation and Finance Taxpayer Services Division Technical Services Bureau STATE OF NEW YORK COMMISSIONER OF TAXATION AND FINANCE ADVISORY OPINION PETITION NO. I970821A On August

More information

Section 404.--Deduction for Contributions of an Employer to an Employees Trust or Annuity Plan and Compensation Under a Deferred Payment Plan

Section 404.--Deduction for Contributions of an Employer to an Employees Trust or Annuity Plan and Compensation Under a Deferred Payment Plan Part I Section 404.--Deduction for Contributions of an Employer to an Employees Trust or Annuity Plan and Compensation Under a Deferred Payment Plan (Also, 401, 412, 6011, 6111, 6112; 26 CFR 1.401-1, 1.412(i)-1,

More information

Differential Earnings Rate for Mutual Life Insurance Companies. This notice publishes a tentative determination under 809

Differential Earnings Rate for Mutual Life Insurance Companies. This notice publishes a tentative determination under 809 Part III Differential Earnings Rate for Mutual Life Insurance Companies Notice 2001-24 This notice publishes a tentative determination under 809 of the Internal Revenue Code of the "differential earnings

More information

Tax Aspects of Settlements and Judgments

Tax Aspects of Settlements and Judgments Tax Aspects of Settlements and Judgments Dominic L. Daher, MAcc, JD, LLM in Taxation Director of Internal Audit and Tax Compliance Adjunct Professor of Law University of San Francisco Dawn G. Mayer, JD,

More information

Internal Revenue Service Number: 200405009 Release Date: 01/30/2004 Index Number: 355.04-00

Internal Revenue Service Number: 200405009 Release Date: 01/30/2004 Index Number: 355.04-00 Internal Revenue Service Number: 200405009 Release Date: 01/30/2004 Index Number: 355.04-00 --------------------- -------------------------------- --------------------------------------------------- --------------------------------------

More information

INTERNAL REVENUE SERVICE Index No.: 115.02-00. Number: 199923029 Release Date: 6/11/1999. CC:DOM:FI&P:1 - PLR-116624-98 March 11, 1999 LEGEND:

INTERNAL REVENUE SERVICE Index No.: 115.02-00. Number: 199923029 Release Date: 6/11/1999. CC:DOM:FI&P:1 - PLR-116624-98 March 11, 1999 LEGEND: INTERNAL REVENUE SERVICE Index No.: 115.02-00 Number: 199923029 Release Date: 6/11/1999 CC:DOM:FI&P:1 - PLR-116624-98 March 11, 1999 LEGEND: Authority = State A = Year 1 = County = Date 1 = Program = Date

More information

CIRA Tax Principles. Agenda. Code and Case References for Condo and HOA Taxation. John Barbery, CPA, MST Mark Brechbill, CPA

CIRA Tax Principles. Agenda. Code and Case References for Condo and HOA Taxation. John Barbery, CPA, MST Mark Brechbill, CPA CIRA Tax Principles Code and Case References for Condo and HOA Taxation John Barbery, CPA, MST Mark Brechbill, CPA Agenda Understanding the Basics Common CIRA tax principles Form 1120-H issues (Section

More information

1. Whether a shareholder and CEO of a company is subject to tax on the exchange of old

1. Whether a shareholder and CEO of a company is subject to tax on the exchange of old Office of Chief Counsel Internal Revenue Service Memorandum Number: 20131601F Release Date: 4/19/2013 CC:LB&I:HMT:NEW:1:NConnelly POSTF-123943-11 date: February 19, 2012 to: Angela Nyagu Internal Revenue

More information

FOR OFFICIAL USE ONLY

FOR OFFICIAL USE ONLY APPEALS INDUSTRY SPECIALIZATION PROGRAM COORDINATED ISSUE PAPER ISSUE: INDUSTRY: COORDINATOR: MINING INDUSTRY WHETHER COSTS INCURRED DURING A STRIKE ARE DEDUCTIBLE FROM GROSS INCOME FROM THE PROPERTY FOR

More information

Parent = Subsidiary = Taxpayer = QI = Bank = Administrator = A = B = Lease Program 1 = Lease Program 2 =

Parent = Subsidiary = Taxpayer = QI = Bank = Administrator = A = B = Lease Program 1 = Lease Program 2 = ,QWHUQDO5HYHQXH6HUYLFH Number: 200240049 Release Date: 10/4/2002 Index No.: 1031.05-00 Department of the Treasury Washington, DC 20224 Person to Contact: Telephone Number: (202) 622-4950 Refer Reply To:

More information

The Internal Revenue Service and the Treasury Department are aware of types

The Internal Revenue Service and the Treasury Department are aware of types Part III Administrative, Procedural, and Miscellaneous Tax-Exempt Leasing Involving Defeasance Notice 2005-13 The Internal Revenue Service and the Treasury Department are aware of types of transactions,

More information

PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE.

PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE. PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE. T.C. Summary Opinion 2007-137 UNITED STATES TAX COURT MICHELE K. GARNER AND ROGER ALLEN

More information

This revenue procedure specifies the conditions under which the Internal Revenue

This revenue procedure specifies the conditions under which the Internal Revenue Part III Administrative, Procedural, and Miscellaneous 26 CFR 601.201: Rulings and determination letters. (Also Part I, 267, 511, 512, 707, 761, 856, 1031, 1361; 1.761-1, 1.761-2; 301.7701-1, 301.7701-2,

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Department of the Treasury Number: 200236028 Release Date: 9/6/2002 Index Numbers: 167.28-00 168.18-00 Washington, DC 20224 Person to Contact: Telephone Number: Refer Reply To:

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Number: 200938018 Release Date: 9/18/2009 Index Number: 61.00-00, 817.00-00 -------------------- ---------------------------------- ----------------------------------------------------

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Index Number: 302.03-00, 355.00-00 302.02-00, 355.04-00 Number: 199923011 Release Date: 6/11/1999 Department of the Treasury Washington, DC 20224 Person to Contact: Telephone Number:

More information

The Sale of Structured Settlements in Minnesota

The Sale of Structured Settlements in Minnesota The Sale of Structured Settlements in Minnesota Structured Settlements The term structured settlement is defined in Minnesota statutes as an arrangement: for the periodic payment of damages for personal

More information

ISSUES. (1) When are attorney s fees paid by an employer as part of a settlement agreement with a former employee subject to employment taxes?

ISSUES. (1) When are attorney s fees paid by an employer as part of a settlement agreement with a former employee subject to employment taxes? Office of Chief Counsel Internal Revenue Service Memorandum Release Number: 20133501F Release Date: 8/30/2013 CC:TEGE:FS:MABAL:MRLenius POSTF-129928-13 Release Number: Release Date: 8/30/2013 date: July

More information

memorandum Office of Chief Counsel Internal Revenue Service Number: 201533011 Release Date: 8/14/2015 CC:FIP:B04 POSTF-146000-13

memorandum Office of Chief Counsel Internal Revenue Service Number: 201533011 Release Date: 8/14/2015 CC:FIP:B04 POSTF-146000-13 Office of Chief Counsel Internal Revenue Service memorandum Number: 201533011 Release Date: 8/14/2015 CC:FIP:B04 POSTF-146000-13 UILC: 832.00-00, 162.04-03 date: May 06, 2015 to: from: Gwen Schoen Attorney

More information

SETTLEMENTS AND JUDGMENTS YOU MEAN I HAVE TO PAY TAXES?

SETTLEMENTS AND JUDGMENTS YOU MEAN I HAVE TO PAY TAXES? SETTLEMENTS AND JUDGMENTS YOU MEAN I HAVE TO PAY TAXES? By: Geoffrey N. Taylor, Esq. I. INCOME TO PLAINTIFF A. Distinction between settlements and judgments. B. Basic rule is the origin of claims test.

More information

105-228.4: Recodified as 58-6-7 by Session Laws 1995, c. 360, s. 1(c).

105-228.4: Recodified as 58-6-7 by Session Laws 1995, c. 360, s. 1(c). Article 8B. Taxes Upon Insurance Companies. 105-228.3. Definitions. The following definitions apply in this Article: (1) Article 65 corporation. - A corporation subject to Article 65 of Chapter 58 of the

More information

LEGEND. Corp 1 = Corp 2 = Corp 3 = Corp 4 = Corp 5 = Corp 6 =

LEGEND. Corp 1 = Corp 2 = Corp 3 = Corp 4 = Corp 5 = Corp 6 = Internal Revenue Service Number: 200350015 Release Date: 12/12/2003 Index No.: 118.01-02 118.02-00 Department of the Treasury P.O. Box 7604 Ben Franklin Station Washington, DC 20044 Person to Contact:

More information

INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE. DEBORAH A. BUTLER ASSISTANT CHIEF COUNSEL (Field Service) CC:DOM:FS

INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE. DEBORAH A. BUTLER ASSISTANT CHIEF COUNSEL (Field Service) CC:DOM:FS DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE WASHINGTON, D.C. 20224 June 12, 2000 Number: 200043011 Release Date: 10/27/2000 CC:DOM:FS:FI&P WTA-N-107454-00 UILC: 162.04-03 INTERNAL REVENUE SERVICE

More information

Private Letter Ruling 9118040, 2/07/1991, IRC Sec(s). 2055

Private Letter Ruling 9118040, 2/07/1991, IRC Sec(s). 2055 Private Letter Ruling 9118040, 2/07/1991, IRC Sec(s). 2055 Date: February 7, 1991 CC:P&SI:Br.4/TR-31-2698-90 Re: *** Dear = *** This is in response to your letter dated December 31, 1990, and prior submissions

More information

PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE.

PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE. PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE. T.C. Summary Opinion 2007-69 UNITED STATES TAX COURT REINALDO & ERNESTINA MORACEN, Petitioners

More information

GUIDE FOR TAX REPORTING AND WITHHOLDING OF SETTLEMENT AWARDS

GUIDE FOR TAX REPORTING AND WITHHOLDING OF SETTLEMENT AWARDS GUIDE FOR TAX REPORTING AND WITHHOLDING OF SETTLEMENT AWARDS Office of the State Controller State of Colorado Revised January, 1997 I. Purpose The purpose of this guide is to provide information necessary

More information

26 CFR 1.1032-1: Disposition by a corporation of its own capital stock. (Also 701, 704, 705, 721, 722, 723, 1001, 1011; 1.701-2(e), 1.704-3.

26 CFR 1.1032-1: Disposition by a corporation of its own capital stock. (Also 701, 704, 705, 721, 722, 723, 1001, 1011; 1.701-2(e), 1.704-3. Part I Section 1032. Exchange of Stock For Property 26 CFR 1.1032-1: Disposition by a corporation of its own capital stock. (Also 701, 704, 705, 721, 722, 723, 1001, 1011; 1.701-2(e), 1.704-3.) Rev. Rul.

More information

This notice is to alert taxpayers and organizations described in 170(c) of the

This notice is to alert taxpayers and organizations described in 170(c) of the Part III - Administrative, Procedural, and Miscellaneous Charitable Split-Dollar Insurance Transactions Notice 99-36 This notice is to alert taxpayers and organizations described in 170(c) of the Internal

More information

Employment Tax Considerations for Businesses When Addressing Litigation with Employees or Former Employees

Employment Tax Considerations for Businesses When Addressing Litigation with Employees or Former Employees Employment Tax Considerations for Businesses When Addressing Litigation with Employees or Former Employees William Hays Weissman Littler Mendelson, P.C. San Francisco, California It is a common fact of

More information

PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE.

PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE. PURSUANT TO INTERNAL REVENUE CODE SECTION 7463(b),THIS OPINION MAY NOT BE TREATED AS PRECEDENT FOR ANY OTHER CASE. T.C. Summary Opinion 2001-156 UNITED STATES TAX COURT RONALD W. RAMEY AND JONI J. RAMEY,

More information

UNITED STATES TAX COURT. SARA J. BURNS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Docket No. 11924-04. Filed September 12, 2007.

UNITED STATES TAX COURT. SARA J. BURNS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Docket No. 11924-04. Filed September 12, 2007. T.C. Memo. 2007-271 UNITED STATES TAX COURT SARA J. BURNS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 11924-04. Filed September 12, 2007. John W. Sunnen, for petitioner. Erin

More information

Abusive Trust Arrangements Utilizing Cash Value Life Insurance Policies Purportedly to Provide Welfare Benefits

Abusive Trust Arrangements Utilizing Cash Value Life Insurance Policies Purportedly to Provide Welfare Benefits Part III. -- Administrative, Procedural and Miscellaneous Abusive Trust Arrangements Utilizing Cash Value Life Insurance Policies Purportedly to Provide Welfare Benefits Notice 2007-83 The Internal Revenue

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Index Number: 61.53-00 and 79-00.00 Department of the Treasury Washington, DC 20224 Number: 200033011 Release Date: 8/18/2000 Person to Contact: Telephone Number: Refer Reply To:

More information

Federal Income Taxation Chapter 3 Compensation for Losses

Federal Income Taxation Chapter 3 Compensation for Losses Presentation: Federal Income Taxation Chapter 3 Compensation for Losses Professors Wells August 26, 2015 Clark v. Commissioner p.90 Facts: Clark paid $19,941.10 by tax counsel to compensate Clark for consequences

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Number: 201122014 Release Date: 6/3/2011 Index Number: 856.01-00 ------------- - ----- Department of the Treasury Washington, DC 20224 Person To Contact: ------------------, ID

More information

Taxable Bonds = -------------------------------------------------------------------------------- ------------------------------

Taxable Bonds = -------------------------------------------------------------------------------- ------------------------------ Number: 200641002 Release Date: 10/13/2006 Internal Revenue Service Index Number: 141.00-00, 141.01-02, 141.02-00 ----------------------------- ------------------------------- ------------------------------------------------------------

More information

Taking Medical Expense Deductions Before and After a Personal Injury Suit

Taking Medical Expense Deductions Before and After a Personal Injury Suit Your Pacific Northwest Law Firm Focus: Structured Settlements Taking Medical Expense Deductions Before and After a Personal Injury Suit By JEREMY BABENER Previously published as Taking Medical Expense

More information

26 CFR 1.263(a)-1: Capital expenditures; in general. (Also 162, 165, 167, 263A; 1.165-3, 1.167(a)-8, 1.167(a)-11, 1.263A-1)

26 CFR 1.263(a)-1: Capital expenditures; in general. (Also 162, 165, 167, 263A; 1.165-3, 1.167(a)-8, 1.167(a)-11, 1.263A-1) Part I Section 263. Capital Expenditures 26 CFR 1.263(a)-1: Capital expenditures; in general. (Also 162, 165, 167, 263A; 1.165-3, 1.167(a)-8, 1.167(a)-11, 1.263A-1) Rev. Rul. 2000-7 ISSUE If the retirement

More information

Internal Revenue Service Index No.: 2518.01-02. Number: 199932042 Release Date: 8/13/1999. Re:

Internal Revenue Service Index No.: 2518.01-02. Number: 199932042 Release Date: 8/13/1999. Re: Internal Revenue Service Index No.: 2518.01-02 Number: 199932042 Release Date: 8/13/1999 Department of the Treasury P.O. Box 7604 Ben Franklin Station Washington, DC 20044 Person to Contact: Telephone

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Number: 201515012 Release Date: 4/10/2015 Index Number: 1381.00-00 --------------------------------------------------- ---------------------------------------------------------

More information

NC General Statutes - Chapter 97 Article 4 1

NC General Statutes - Chapter 97 Article 4 1 Article 4. North Carolina Self-Insurance Security Association. 97-130. Definitions. As used in this Article: (1) "Association" means the North Carolina Self-Insurance Security Association established by

More information

REIT; DIVIDENDS PAID DEDUCTION; REINVESTMENT PLAN

REIT; DIVIDENDS PAID DEDUCTION; REINVESTMENT PLAN Rev. Rul. 2002- [Ruling that discount is not a dividend] ISSUE REIT; DIVIDENDS PAID DEDUCTION; REINVESTMENT PLAN What are the Federal income tax consequences arising from the issuance of shares of a publiclytraded

More information

GENERAL ASSEMBLY OF NORTH CAROLINA SESSION 1999 SESSION LAW 1999-367 SENATE BILL 746

GENERAL ASSEMBLY OF NORTH CAROLINA SESSION 1999 SESSION LAW 1999-367 SENATE BILL 746 GENERAL ASSEMBLY OF NORTH CAROLINA SESSION 1999 SESSION LAW 1999-367 SENATE BILL 746 AN ACT TO CREATE THE NORTH CAROLINA STRUCTURED SETTLEMENT PROTECTION ACT. The General Assembly of North Carolina enacts:

More information

DEPARTMENTAL INTERPRETATION AND PRACTICE NOTES NO. 14 (REVISED) PROPERTY TAX

DEPARTMENTAL INTERPRETATION AND PRACTICE NOTES NO. 14 (REVISED) PROPERTY TAX Inland Revenue Department Hong Kong DEPARTMENTAL INTERPRETATION AND PRACTICE NOTES NO. 14 (REVISED) PROPERTY TAX These notes are issued for the information of taxpayers and their tax representatives. They

More information

Xxxxxxxxxxxxxxxx Xxxxxxxxxxxxxxxx

Xxxxxxxxxxxxxxxx Xxxxxxxxxxxxxxxx DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE WASHINGTON, D.C. 20224 201432038 TAX EXEMPT AND GOVERNMENT ENTITIES DIVISION MAY 1 5 2014 Uniform Issue List: 408.03-00 Legend: Taxpayer A IRA X IRAY

More information

T.C. Memo. 2015-47 UNITED STATES TAX COURT. BALVIN ANTHONY MCKNIGHT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

T.C. Memo. 2015-47 UNITED STATES TAX COURT. BALVIN ANTHONY MCKNIGHT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent T.C. Memo. 2015-47 UNITED STATES TAX COURT BALVIN ANTHONY MCKNIGHT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20844-13. Filed March 16, 2015. Balvin Anthony McKnight, pro se.

More information

DEDUCTIBILITY OF LEGAL FEES. By: Melvin Sternberg, Esq. Certified Specialist in Family Law Sternberg & Singer, Ltd.

DEDUCTIBILITY OF LEGAL FEES. By: Melvin Sternberg, Esq. Certified Specialist in Family Law Sternberg & Singer, Ltd. DEDUCTIBILITY OF LEGAL FEES By: Melvin Sternberg, Esq. Certified Specialist in Family Law Sternberg & Singer, Ltd. 1 INTRODUCTION Deductions being a matter of legislation, it is necessary to relate any

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Number: 201145005 Release Date: 11/10/2011 Index Number: 141.07-00 -------------------------------------------------------- ------------------------------- ------------------------

More information

WOODCRAFT. tax notes. Can Class Action Attorney Fees Be Structured? By Robert W. Wood

WOODCRAFT. tax notes. Can Class Action Attorney Fees Be Structured? By Robert W. Wood Can Class Action Attorney Fees Be Structured? By Robert W. Wood Robert W. Wood practices law with Wood & Porter in San Francisco (http://www.woodporter.com) and is the author of Taxation of Damage Awards

More information

INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE MEMORANDUM FOR

INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE MEMORANDUM FOR INTERNAL REVENUE SERVICE Number: 200102004 Release Date: 1/12/2001 CC:IT&A:01/TL-N-2327-00 UILC: 446.04-03 August 14, 2000 INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE MEMORANDUM FOR FROM:

More information

INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM. Taxpayer s Name: Taxpayer s Address:

INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM. Taxpayer s Name: Taxpayer s Address: INTERNAL REVENUE SERVICE NATIONAL OFFICE TECHNICAL ADVICE MEMORANDUM Number: 200101001 Release Date: 1/5/2001 Third Party Contact: None Index (UIL) No.: 166.03-00 CASE MIS No.: TAM-103260-00/CC:ITA:B6

More information

At your request, we have examined three alternative plans for restructuring Gapple s

At your request, we have examined three alternative plans for restructuring Gapple s MEMORANDUM TO: Senior Partner FROM: LL.M. Team Number DATE: November 18, 2011 SUBJECT: 2011 Law Student Tax Challenge Problem At your request, we have examined three alternative plans for restructuring

More information

Annuity and Life Insurance Contracts with a Long-Term Care Insurance Feature. This notice relates to amendments made to 72, 1035, and 7702B of the

Annuity and Life Insurance Contracts with a Long-Term Care Insurance Feature. This notice relates to amendments made to 72, 1035, and 7702B of the Part III - Administrative, Procedural, and Miscellaneous Annuity and Life Insurance Contracts with a Long-Term Care Insurance Feature Notice 2011-68 SECTION 1. PURPOSE This notice relates to amendments

More information

Fund = Corporation = Act A = Act B =

Fund = Corporation = Act A = Act B = Internal Revenue Service Department of the Treasury Number: 200140032 Release Date: 10/5/2001 Index Numbers: 7701.20-00 0170.07-05 Washington, D.C. Person to Contact: Telephone Number: ) Refer Reply to:

More information

TAX TREATMENT OF RECOVERIES IN EMPLOYMENT DISPUTES

TAX TREATMENT OF RECOVERIES IN EMPLOYMENT DISPUTES TAX TREATMENT OF RECOVERIES IN EMPLOYMENT DISPUTES Committee on Labor & Employment Law AUGUST 2009 THE ASSOCIATION OF THE BAR OF THE CITY OF NEW YORK 42 WEST 44 TH STREET, NEW YORK, NY 10036 TAX TREATMENT

More information

TABLE OF CONTENTS Surety Bond Guarantee Program for Small Contractors

TABLE OF CONTENTS Surety Bond Guarantee Program for Small Contractors Department of Economic Development Sec. 32-55 page 1 (9-97) TABLE OF CONTENTS Surety Bond Guarantee Program for Small Contractors Definitions.... 32-55-1 Eligibility... 32-55-2 Guarantee agreement... 32-55-3

More information

Internal Revenue Service

Internal Revenue Service Internal Revenue Service Number: 201246008 Release Date: 11/16/2012 Index Number: 1362.00-00, 1362.04-00 ----------------------------------------- ----------------------------------------- ------------------------------------------------

More information

Structured Attorney s Fees

Structured Attorney s Fees STRUCTURED SETTLEMENTS Structured Attorney s Fees Preparing for Your Financial Future 7/13 26169-13B Table of Contents Managing Your Retirement... 2 The Power of Tax Deferral... 3 Structured Attorney s

More information

INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE MEMORANDUM FOR DISTRICT COUNSEL

INTERNAL REVENUE SERVICE NATIONAL OFFICE FIELD SERVICE ADVICE MEMORANDUM FOR DISTRICT COUNSEL DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE WASHINGTON, D.C. 20224 September 22, 1999 Number: 199952011 Release Date: 12/30/1999 CC:DOM:FS:FI&P TL-N-2896-99 UILC: 832.06-02 INTERNAL REVENUE SERVICE

More information