Tax
Jan. 11, 2023
IRS targets structured fee tax deferrals for plaintiff lawyers
The IRS does not have the power to outvote the Tax Court or Eleventh Circuit, but it has the power to audit.
Robert W. Wood
Managing Partner
Wood LLP
333 Sacramento St
San Francisco , California 94111-3601
Phone: (415) 834-0113
Fax: (415) 789-4540
Email: wood@WoodLLP.com
Univ of Chicago Law School
Wood is a tax lawyer at Wood LLP, and often advises lawyers and litigants about tax issues.
It would be difficult to overstate the surprise from insurance companies, structured settlement providers, settlement brokers, and plaintiff lawyers from the release in December 2022 of IRS General Legal Advice Memorandum, AM 2022-007, known in tax parlance as a GLAM. The only known attack on structured legal fees came in 1994, when the IRS was rebuffed by the Tax Court and 11th Circuit in the seminal case of Childs v. Commissioner 103 T.C. 634 (1994), aff'd w...
For only $95 a month (the price of 2 article purchases)
Receive unlimited article access and full access to our archives,
Daily Appellate Report, award winning columns, and our
Verdicts and Settlements.
Or
$795 for an entire year!
Or access this article for $45
(Purchase provides 7-day access to this article. Printing, posting or downloading is not allowed.)
Already a subscriber?
Sign In