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1 Presenting a live 90 minute webinar with interactive Q&A Structured Settlements and Deferred Attorney Fees Leveraging Structured Arrangements to Protect the Client, Facilitate Case Resolution, and Provide Tax Deferred Benefits for Counsel TUESDAY, MARCH 1, pm Eastern 12pm Central 11am Mountain 10am Pacific Td Today s faculty features: Brian Michaels, General Counsel, Brook Hollow Financial, Chicago Christopher J. Princis, Senior Vice President, Brook Hollow Financial, Chicago Robert W. Wood, Partner, Wood & Porter, San Francisco The audio portion of the conference may be accessed via the telephone or by using your computer's speakers. Please refer to the instructions ed to registrants for additional information. If you have any questions, please contact Customer Service at ext. 10.

2 Conference Materials If you have not printed the conference materials for this program, please complete the following steps: Click on the + sign next to Conference Materials in the middle of the left- hand column on your screen. Click on the tab labeled Handouts that appears, and there you will see a PDF of the slides for today's program. Double click on the PDF and a separate page will open. Print the slides by clicking on the printer icon.

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4 Tips for Optimal Quality Sound Quality If you are listening via your computer speakers, please note that the quality of your sound will vary depending on the speed and quality of your internet connection. If the sound quality is not satisfactory and you are listening via your computer speakers, you may listen via the phone: dial and enter your PIN when prompted. Otherwise, please send us a chat or immediately so we can address the problem. If you dialed in and have any difficulties during the call, press *0 for assistance. Viewing Quality To maximize your screen, press the F11 key on your keyboard. To exit full screen, press the F11 key again.

5 After Settlement Success What You Need to Know Brian S. Michaels, Esq. General Counsel, Brook Hollow Financial Christopher J. Princis Senior Vice President, Brook Hollow Financial Robert W. Wood Partner Wood & Porter Partner, 5

6 Agenda 1. Settlement Funds/468B/QSF 2. Deferred Attorney Fees 3. Structured Settlements 4. Wrap-up 6

7 Challenges With Multi Multi-Party Party Settlements Multiple Defendants Varying settlement timeframes Multiple Plaintiffs/Claimants Varying settlement timeframes Liens Multiple Law Firms Attorney Fee Opportunities Structured Settlement Issues 7

8 S l ti Solution: Qualified Settlement Fund IRC Section 468B 8

9 Qualified Settlement Funds (1 of 2) Qualified Settlement Funds (( QSFs )) were established by Congress. Fund is established and defendant pays i t the into th ffund, d gets t a release l off liability li bilit and tax deduction. Allows plaintiff(s) to settle case and receive payment from defendant without triggering constructive receipt of the funds. Routinely used in class actions and mass tort cases of all sizes and comple it complexity. 9

10 Qualified Settlement Funds (2 of 2) 3 Requirements to be treated as a QSF - Order O d approved db by any jjurisdiction. i di ti - Established to resolve 1 or more claims. - Fund is a trust under state law and assets segregated. 10

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12 Cases Where QSFs Have Been Used 100 s of mass tort and class action cases Cook County Building John Hancock Scaffolding 50+ plaintiffs 50 l i tiff Multitude of unresolved issues $78 million 18 plaintiffs 20+ d 20 defendants, f d t all paying at different times 12

13 Opportunities pp For Using g QSF QSF by Case/Firm Law Fi L Firm establishes t bli h own QSF similarly situated cases QSF by Case/Multiple Firms Each firm establishes own subqsf (Avandia) Other Why? Liens, administration, deferred attorney fees, f structured settlements, SNTs, etc. Away from eyes/influence of defense Makes everything easier 13

14 Deferred Attorney Fees 14

15 Let s Clarify ANY contingent fee can be deferred (not just personal injury) Attorney can defer their contingent fee REGARDLESS if client chooses a structured settlement. Create custom portfolio with any investment option! 15

16 Deferred fees continued Authorized by Childs v. Commissioner (2103 T.C. 634, 94 TNT (1994), and affirmed by the 11th Circuit U.S. Federal Appeals Court in Childs v. Commissioner, (aff d without opinion) p ) 89 F.3d 856, Doc , 96 TNT (11th Cir. 1996)). Payable Directly to the Law Firm or Attorney Can structure all or a portion of the fee 16

17 Why Structure Attorney Fees? Income Tax Deferral. This is an excellent tool to smooth out income from year to year and minimize problems such as the Alternative Minimum Tax and phase-outs with the very real possibility p y of lowering g taxes actually yp paid. Retirement Planning. 100% of income can be structured. Unlike other retirement plans there is no income limit limit, on participation rules and no annual administrative costs. It has been described as an uncapped 401(K) plan. Overhead Expenses. Law firms have used structured attorney fees to provide for future law firm overhead expenses. By structuring a portion of current fees (or a portion of big blips in income) firms have lowered reliance on lines of credit for future operating costs. 17

18 Taxable Equivalent Analysis: What you have to earn to match the power of deferral 18

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21 Structuring Contingent Attorney Fee: Procedural Steps 1. Client and Attorney Fee Agreement 2. Plaintiff and Defendant Agree on Settlement 3. Parties Meet With Settlement Specialist to Determine Amount and Timing of Payments 4 Plaintiff Executes Settlement Agreement and 4. Release, with Attorney Fee payable in Exchange for 5 D 5. Defendants f d t P Promises i tto M Make k F Future t Periodic Payments to Attorney for fee 6. Defendant Assigns g Obligation g to Make Future Payments to Assignment Company 21

22 Structuring St t i C Contingent ti t Att Attorney Fee: F Procedural Steps 7. Defendant Transfers Cash to Assignment Company 8. Assignment g Company p y Uses Cash to Purchase Investments to Fund Future Payments 9. Assignment Company (or their Custodian) Makes Future Periodic Payments to Plaintiff Attorney 10. Guarantee of the Performance of the Qualified g is Issued Assignee 11. Attorney can structure their fee regardless of what client does with their settlement 22

23 Deferred Attorney Fees Legal Representation Client Attorneyy Pay Fee in Cash +/or Promise of Future Periodic Payments Key Point: Legal fee agreement between p for Client and Attorneyy should provide payment of contingent fee in form of lump sum and/or future periodic payments. 23

24 Deferred Attorney Fees cont cont Cash + Promise of Future Periodic Payments Attorney Defendant Settlement Agreement and Release Future Periodic P Payments t Cash Liability to make Future Periodic Payments Investment(s) Investment Provider Assignment Company Cash 24

25 Legal and Tax History Pre-Childs TAMs , , IRS said FMV of payment rights includible in attorney ss current year tax attorney Childs v. Commissioner The seminal structured attorney fee case 103 T.C. 634, 94 TNT (1994), aff d without opinion 89 F.3d 856, (11th Cir. 1996). IRS has not formally y acquiesced, q, Tax Court bound by Childs in 11th Circuit, even so, Tax Court usually follows published guidance from another Circuit where no other published guidance exists exists 25

26 Legal History cont cont. Post-Childs No cases or rulings to our knowledge since Childs IRS has cited Childs favorably Rev. Rul , IRB 1052, Doc , 2003 TNT No constructive receipt where irrevocable election and substantial limitations or restrictions FSA Cites Childs, attorney has no constructive receipt where settlement is entered into before attorney has unconditional right to receive fee PLR No constructive receipt employment settlement 26

27 Childs v. Commissioner Facts Flows from a case where a house blew up b/c of propane gas with one person seriously injured and one death Plaintiff Lawyers agree to periodic payments for portion of legal fees Provided for in settlement agreement with assignment of liability to 3rd party assignee Assignment company purchased annuity to fund future payments Lawyer(s) named annuitants of the annuities and estates named beneficiaries Annuity subject to rights of general creditor, however insurance company guaranteed performance of the assignment company Lawyers had no right to accelerate payments and no rights greater than a general creditor Issue(s) When are the attorney fees includible by the attorney i hi in his ttaxable bl iincome?? Holding The Tax Court ((affirmed byy the 11th Circuit)) held that the attorneys did not constructively receive the fees in the year the settlement documents were signed. 27

28 Childs v. Commissioner Tax Court Holding(s): 1. HELD: The fair market values of Ps' rights to receive payments under the settlement agreements were not includable in income under sec. 83, I.R.C. in the year in which the settlement agreements were effected, since the promises to pay under the structured settlements were neither funded nor secured and thus did not meet the definition of property for purposes of sec HELD, FURTHER, the doctrine of constructive receipt is inapplicable, since Ps had no right to receive the attorney's fees prior to the time the agreement fixing a structured settlement was entered into into. 11th Circuit Holding: - Affirmed Affi d th the T Tax Court C t in i a one page d decision. i i 28

29 Technical Requirements q of Deferred Attorney Fee FORM is important with tax do it right on the front end! No constructive receipt No IRC Section 409A No economic benefit Work with a highly g y qualified advisor 29

30 Tax Issues and/or Consequences to Attorney s Attorney s Client and Defendant Client/Claimant/Plaintiff IRC 104 case no taxation issues/consequences as proceeds are tax free Non IRC 104 case Settlement proceeds taxable Structure can lower overall tax paid significantly Attorney fees included in income of client, see Commissioner v. Banks and Commissioner v. Banaitis, 175 S.Ct. 826; 2005 U.S. Lexis 1370 (2005) 2004, P P.L. L American Jobs Creation Act of 2004 Certain cases get above the line deduction, which effectively nets out the attorney fees» False Claims Act and Section 1862(b)(3)(A) of S i ls Social Security it A Act, t and d» A long list of laws that provide for employment claims Certain other cases do not get above the line deduction, but get itemized deduction subject to 2% floor (with no deduction for AMT purposes) gross method 30

31 Tax Issues and/or Consequences to Attorney s Attorney s Client and Defendant This can lead to bad tax result - see Spina vv. Forest Preserve District of Cook County County, 207 F. Supp.2d 764 (N.D. Ill. 2002) as reported in 2002 National Taxpayer Advocate Report to Congress at 166. See Adam Liptak, Tax Bill Exceeds Award to Officer in Sex Bias Case, The New York Times, Aug. 11, 2002, section 1, p. 18.Cynthia Spina v This is an illustrative case, this specific case would differ after Jobs Act, however for non 104 cases that do not have Jobs Act protection, this would still be the bad tax result - Structuring attorney fees can help client by spreading out attorney fee income over a number of years 31

32 Tax Issues and/or Consequences to Attorney s Attorney s Client and Defendant Defendant gets deduction, issue is when IRS Notice and Maxus Energy gy Corporation p and Subsidiaries v. United States, 31 F.3d 1135 (Fed. Cir. 1994). In Notice , the Service cited Maxus Energy Corporation and Subsidiaries v. United States saying that a taxpayer s taxpayer s payment to a settlement fund effectively constitute[s] payment to the person to which the liability [is] owed [if] the claimants agree[ ] to look solely to the fund to satisfy their claims, and therefore, the taxpayer s payment to the fund discharge[s] its liability to the claimant. Qualified Settlement Se e e Fund u d (IRC ( C Section Sec o 468B) 68 ) Payment by a defendant to an assignment company would be treated as a payment to the person to which the liability is owed under Treas. Reg (g)(1) if the payment to the assignment company extinguishes the defendant s liability to the claimant. Structured attorney fees typically (they should) involve a novation, therefore a defendant would be able to claim an immediate deduction upon making the lump sum payment to the assignment company, just as if the defendant had instead paid that lump sum amount directly to the claimant 32

33 Tax Issues and/or Consequences to Attorney s Attorney s Client and Defendant Defendant s Insurer g get deduction when paid Whether directly to plaintiff/claimant, To a QSF, or Structured Attorney Fee, or Structured Settlement See IRC Sections

34 Structured S ttl Settlements t 34

35 Why Talk About S Structured Settlements? S? Must be completed p at time of settlement After docs signed it is too late! Often offered by defense Understand what is being offered Resource to call to evaluate the structure being offered Plaintiff/plaintiff attorney can and should have own structured settlement consultant Understand Benefits Understand Limitations 35

36 The Settlement Industry Approximately 600 full-time structured settlement consultants nationwide Most are primarily defense oriented But, most also work with plaintiffs Plaintiff only brokers Plaintiff has right to their own consultant O Only l properly l lilicensed d consultants lt t can offer structured settlements Not unlicensed financial planners, brokers, etc. Structured settlements are specialized Trade Association: National Structured Settlements Trade Association (www.nssta.org) 36

37 Structured Settlement The settlement of a claim or a lawsuit through cash payments th t are made that d on an installment i t ll t or periodic basis Usually a mix of immediate cash and deferred lump sums and/or monthly payments 37

38 Structured Settlement Benefits Eliminate the risk of mismanagement. According to one recent study, approximately 90% spend all their settlement moneyy within five yyears. Provide tax advantages. Fixed annuity payments from a qualified structured settlement are tax-free to the annuitant under current IRS rules. Provide a steady, low-risk source of money. Structures eliminate the expense and worry of managing large sums. Offer more money over time Off ti than th a lump l sum. Fixed annuity payments can continue for life no matter how long the claimant lives. Customized p payments. y Structures offer a convenient way to meet the individual claimant s needs and special circumstances. Maximize settlement benefits. In cases where the defendant has low insurance policy limits, a structured settlement can often provide a more generous overall settlement. 38

39 Structured Settlement Benefits Tax-free Structured Settlement funds are exempt from federal and d state t t income i taxes. t You Y can avoid id th the ttax burden b d that comes with investment earnings on a cash settlement. Over time, a structured settlement ensures significant tax savings and maximizes the value of the settlement proceeds. No market risk Exposure to market risks is eliminated along with the potential for investment failures. The annuity provider absorbs any risk of market and interest rate fluctuations fluctuations, and the dollar amount of the claimant s payments is guaranteed, year after year. Money is available when the claimant needs it most Annuity payments may be designed and timed to meet the claimant s needs now and decades from now. They are assured that funds will be there specifically for medical and educational expenses, for basic living requirements requirements, and for specialized healthcare needs that may arise in the future as a result of their injury. 39

40 Structured Settlement Benefits for Minors Safety and Security p life insurance markets Brook-Hollow Financial onlyy represents that have secured A++ or A+ ratings from the A.M. Best Company. Structured settlements are not subject to the claims of creditors. Structured settlements relieve the burden and expense of money management, investment decisions, and management fees. Structured settlements are protected by strict government regulations. Flexible The benefit payment streams can be designed to meet the future financial needs of the minor. Examples include: funding a college education, lifetime guaranteed payments payments, guaranteed lump sum payments, and even future retirement planning. 40

41 Structured Settlement Benefits for Minors Eliminate the Risk of Mismanagement Because benefits to be paid under a fixed annuity are calculated in advance, d th the plaintiffs l i tiff h have th the security it off kknowing i th the exactt amountt and payment dates of their periodic payments. Structured settlements provide tax free payments. There is no tax due on the principal or earnings distributed to the plaintiff, or their beneficiaries. (IRC 104(a)) Additionall benefits Additi b fit Courts often insist on structures for minors because structures guarantee the highest rate of return of any investment and the funds are set aside solely for the benefit of the minor; the structure cannot be invaded by unscrupulous individuals. There is no need to post a bond or for annual reporting by the parent or guardian. It is virtually impossible for the minor to dissipate the settlement funds once they have attained the age of majority. The minor is still eligible for financial assistance in college. Structures provide an ongoing legacy from a parent to their child. 41

42 Structured Settlements Are Also Useful When Dealing With Claimants Who Have Special Needs Significant, ongoing medical expenses; Rehabilitation or permanent care facility expenses; College tuition, retirement income, the down payment on a home or a mortgage payment, and; Replacement of monthly income, annual income or supplemental income. Workers compensation claims; and Personal injury, other than bodily injury. 42

43 Insurance Companies p Offering g Structured Settlements Company Name All t t Life Allstate Lif Insurance I Company C American General Life Insurance Company John Hancock Life Insurance Company Liberty Life Assurance Company of Boston Metropolitan p Life Insurance Company p y New York Life Insurance Company Pacific Life and Annuity Company Prudential Insurance Company of America Symetra Life Insurance Company A.M. Best Rating - Size A A+ XV A XV A+ XV A X A+ XV A++ XV A+ XV A+ XV A XII 43

44 Structured Settlements Can Be Used In Tax-Free OR Taxable Recovery Cases Tax-free Cases IRC Section 104 All payments ever received are free form federal income taxation Taxable Recoveryy Cases Payments are tax-deferred 44

45 Involve Structured Settlement Consultant Early Minimal Basic Data Needed Case Profile Fact Sheet Medical reports admission/discharge summaries Plaintiff s life care plan p Economist s report 45

46 Brian S. Michaels, Esq., General Counsel Direct: Christopher J. Princis Direct Office: Cell: Robert W. Wood Direct: oodporter com 46

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