Learn the complexities of what makes settlements taxable vs. non-taxable, several strategies to minimize settlement tax liabilities.
Settlements and their tax implications can often seem complex for individuals and businesses. It’s essential to grasp the nuances involving taxation of settlements to make informed decisions and reduce tax burdens.
This article dives into the details of taxation of settlements, offering insights into compensatory damages and punitive damages, as well as how different settlement types, like whistleblower settlements, are treated for tax purposes. This article also discusses strategies for minimizing tax responsibilities on settlements and answers common questions such as how to report settlement funds to the IRS and determining the portion of a taxable settlement.
Per Section 61 of the Internal Revenue Code (IRC), all income is generally taxable unless explicitly exempted by another section of the IRC. The taxation of settlements hinges on the nature of the claim and the damages awarded.
The taxability of settlements is contingent upon “the origin of the claim,” meaning the cause of action that led to the settlement award. Here’s a breakdown illustrating how typical settlements are taxed:
When determining the taxability of a settlement, consider these key factors:
IRC Section 104 excludes certain settlements and awards from taxable income. Specifically, §104(a)(2) of the IRC allows taxpayers to exclude from gross income “the amount of any damages (other than punitive damages) received on account of personal physical injuries or physical sickness.”
However, there are some important nuances to keep in mind:
Before 1996, Section 104(a)(2) did not have the “physical” requirement. The Small Business Job Protection Act of 1996 changed the code to restrict exclusions for injuries and sickness.
PRO TIP: Emotional distress alone does not qualify for the exclusion under §104(a)(2) unless it originates from a physical injury or sickness.
PRO TIP: Attorney fees that come with damages cannot be deducted by the plaintiff. So, the plaintiff will need to pay taxes on the amount of the award. (Refer to the discussion on strategies in the Plaintiff Recovery Trust to avoid this “double tax” situation.)
PRO TIP: Taxpayers must show that their settlement qualifies for exclusion under Section 104(a)(2). The IRS will review the language in the settlement agreement and legal claims to determine tax treatment. Using precise language in both settlement agreements and court orders can strengthen a taxpayer’s case.
Settlements stemming from physical injury or illness are generally deemed nontaxable under Internal Revenue Code (IRC) Section 104 (a)(2). These settlements compensate individuals for injuries or sickness. Let’s look at some examples.
Settlements received for personal physical injuries are typically nontaxable, including compensation for:
The critical factor is that the settlement involves physical injury or sickness. Emotional distress damages originating from a physical injury are also nontaxable.
When a settlement includes reimbursement for expenses related to the injury, the part of the settlement designated for those expenses is usually not taxable unless those medical expenses were previously deducted by the plaintiff. If, in a prior tax year, the medical expenses were deducted and a tax benefit was provided, then that portion of the settlement may be considered income.
Similarly, settlements for death cases are generally treated as nontaxable since they are handled similarly to injury settlements from a tax perspective. These settlements compensate the surviving family members for reasons including the loss of support, the pain and suffering experienced by the deceased, medical and funeral expenses, and the loss of potential inheritance. However, there are exceptions to consider. Punitive damages in cases of wrongful death are typically subject to taxation. Moreover, any part of the settlement that reimburses expenses previously deducted by the plaintiff may be regarded as income up to the extent of any tax benefits received.
PRO TIP: Contingent attorney fees associated with punitive damages are not deductible to the plaintiff. Accordingly, the plaintiff must pay taxes on the entire amount of the punitive award. (Plaintiff recovery Trust discussion below for strategies to eliminate this “double tax”)
Carefully review the specific circumstances of each settlement to determine the appropriate tax treatment. Consulting with a tax professional can help ensure compliance with IRS regulations.
Some settlements are not subject to taxes; however, some require taxation. Let’s delve into some examples of these settlements in detail.
Compensation received for lost wages, back pay, front pay, or severance pay is considered income and is subject to taxes, including Social Security and Medicare taxes (FICA) withholding. Here’s a breakdown of how these settlements are taxed:
It’s crucial to understand that even if some of the settlement pertains to distress damages stemming from an employment dispute, those damages remain taxable unless they result from an injury or illness.
Punitive damages are always taxable regardless of the case’s nature. These damages aim to penalize the defendant for their misconduct and do not serve as compensation for the plaintiff’s losses. Punitive damages are categorized as “Income” on Form 1099 MISC. Are taxed as ordinary income rates.
PRO TIP: Contingent attorney fees associated with punitive damages are not deductible to the plaintiff. Accordingly, the plaintiff must pay taxes on the entire amount of the punitive award. (Plaintiff recovery Trust discussion below for strategies to eliminate this “double tax”)
When it comes to distress without injury, payments received for mental anguish or emotional distress are usually subject to taxation unless they stem from a personal physical injury or illness. These payments may be tax-free if an injury causes emotional distress. However, these payments become taxable if emotional distress leads to symptoms like headaches or stomachaches.
Let’s consider some examples:
When receiving a settlement for emotional distress, it’s crucial to work with a tax professional to determine the appropriate tax treatment based on the specific circumstances of your case.
There is no tax exemption exception for False Claims Act whistleblower awards. As such, whistleblowers must pay income taxes on their rewards at the ordinary income tax rates. As such, it remains wise to seek competent advice, as tax questions regarding whistleblower rewards are complex.
PRO TIP: Federal and state income tax burdens apply to qui tam rewards like any other form of ordinary income.
For those seeking to minimize settlement tax obligations, there are strategies available to reduce the taxes and maximize the recovery for plaintiffs. Utilizing settlement annuities, the Plaintiff Recovery Trust, and proper allocation in settlement agreements can help individuals reduce their tax burden and secure their future.
Structured settlement annuities provide a tax option for recipients of settlements by spreading out the settlement payments over several years instead of receiving a lump sum. This approach helps lower the tax rate. It offers benefits such as tax deferral, guaranteed growth of funds within the annuity, and enhanced financial stability. Regular payments can help secure your future and prevent spending decisions. Different types of annuities offer diverse features:
Moreover, Plaintiff Recovery Trusts (PRTs) are tools to avoid taxation for plaintiffs receiving settlements that include attorney fees. By transferring the litigation interest to the trust, plaintiffs only pay taxes on their recovery as beneficiaries, increasing after-tax earnings by 30 to 70%.
PRTs offer additional benefits:
The tax implications of settlements hinge on the source and nature of the claims involved. By distributing settlement funds in the agreement, plaintiffs can optimize the portion of their recovery exempt from taxes.
By strategically employing structured settlement annuities, plaintiff recovery trusts, and proper allocation in settlement agreements, plaintiffs can significantly minimize their tax obligations and maximize their net recovery, providing long-term financial security and peace of mind.
The tax consequences associated with settlements can be complex and diverse, underscoring the importance for individuals and organizations to grasp the intricacies of taxable versus taxable settlements.
Understanding the basics of damages, punitive damages, and how settlements are taxed can help readers make informed decisions to lower their tax burden. Utilizing methods like settlement annuities, plaintiff recovery trusts, and careful allocation in settlement agreements can cut down on taxes. Increase the final amount received. It’s advisable to seek guidance from tax experts and lawyers to handle the intricacies of settlement taxation in line with IRS rules.
Explore the tax implications of post-judgment interest in personal injury cases. Learn about tax planning strategies and the role of Plaintiff Recovery Trust. Be informed to enhance your legal award tax planning.
You prevailed and won the case, and the award includes post-judgment interest – now, taxes are due on the interest.
Unfortunately, many people are taken aback when they find out that post-judgment interest is always taxable in cases involving injuries.
Knowing how this interest is taxed and being ready for it is often overlooked when planning for matters. This discussion focuses on the tax implications of post-judgment interest in physical injury cases and ways to reduce its tax burden.
The notion that post-judgment interest is not material can be fatally flawed. As the appeals process can drag on for years, it is not at all unusual for post-judgment interest to be significant. In today’s courts, cases with millions of dollars in post-judgment interest are not rare.
Pro-Tip: As time passes, tax planning options diminish. Therefore, the time to start planning to mitigate post-judgment interest taxation is before the case is final – the earlier, the better.
Pro Tip: Taxation of Post Judgement Interest Still Applies Under IRC Section 104. Damages received for injuries or sickness are not taxable gross income under §104(a)(2). However, it’s important to note that this tax exemption does not extend to damages or post-judgment interest. As a result, punitive damages and post-judgment interest are always subject to taxation, irrespective of the type of injury.
Pro Tip: Legal Fees and Deductions.
The 2017 tax law eliminated the deduction for attorney fees linked to awards or settlements. As a result, individuals filing lawsuits now need to include the entire amount of their taxable recoveries as taxable gross income without being able to deduct any legal fees. For more details, click Double Tax.
The Plaintiff Recovery Trust (PRT) allows plaintiffs to reduce the tax implications of taxable awards (including post-judgment interest). This specialized trust enables plaintiffs to skip paying taxes on the attorney fee portion of the judgment or settlement, including those linked to judgment interest. As a result, the PRT offers the advantage of helping plaintiffs retain a greater after-tax percentage of the award.
Structured settlement annuities, while beneficial, offer less effective strategic tools for plaintiffs to reduce the taxation on post-judgment interest. By spreading payments over many years, plaintiffs can spread the realization of the taxable income, which may result in minor tax benefits by lowering the applicable tax rate. However, these tax savings can be illusory, as future federal or state tax rate increases could result in even greater taxation.
Navigating the complexities of post-judgment interest and its tax implications is often an overlooked planning element. The Plaintiff Recovery Trust typically will offer the best taxation outcomes on post-judgment interest awards, and by preplanning to utilize the PRT, recipients can significantly enhance their economic results.
As such, when the possibility exists of court awards with post-judgment interest, one should proactively engage in tax planning strategies EARLY – waiting until after the final award or the appeal is often too late.
Explore our comprehensive guide on private placement escrow accounts including their use with Reg D, Reg A, Reg A+, Reg CF, and Reg S. Understand their role, the escrow process, regulatory frameworks, and the importance of choosing the right escrow agent.
So, you want to conduct a private placement? Whether Reg D, Reg A, Reg A+, Reg CF (Crowdfunding), or Reg S, offering a private placement escrow trust to hold investor funds prior may be required, but it is always a good idea.
Escrow accounts play a vital role in private placement offerings by securely holding investor funds until specific conditions are met, thus offering protection that boosts investor confidence. Opting for a “trust company” over a traditional bank account for escrow purposes introduces the advantage of active independent oversight and more FDIC insurance coverage (up to $150M per account), further enhancing the security and integrity of these escrow transactions.
Using an escrow agent, a neutral third party underscores the commitment to the prudent management of funds in private equity, Reg D, Reg A, Reg A+, Reg CF (Crowdfunding), Reg S offerings, and other private offerings. Another beneficial advantage is that the escrow account increases the confidence of both the offeror and the investor in the outcome. Thus, private placements safeguard investor assets and facilitate smooth transactions with regulatory and private placement offering terms.
Private placement escrow accounts are essential in managing the complexities of private securities transactions. These accounts hold funds raised from investors until the satisfaction of specific offering terms, ensuring compliance with regulatory requirements and safeguarding investor interests.
Private placements operate under the U.S. Securities and Exchange Commission, FINRA, and the associated securities statutes, regulations, and rules, which mandate using a private placement memorandum instead of a prospectus and may restrict marketing to the general public. Specifically, Reg D offerings are only open to accredited investors, adding another layer of complexity. However, Reg A/A+ and Reg CF offerings may be available to non-accredited investors - albeit with other restrictions.
Pro Tip: Always consult with competent legal counsel to safeguard compliance with all pertinent regulations and laws.
A private placement escrow agent acts as an impartial third party, holding in custody the investor funds securely until all conditions of the private placement offering are met. This role is crucial in “all or nothing” contingency offerings, where the closing (breaking escrow) depends on reaching a stated aggregate amount of funding by a specified date. All funds must be returned to the investors if the minimum is unmet.
Investor funds should be placed in escrow to minimize the risk of violating SEC Rules 10b-9 and 15c2-4.
When choosing an escrow agent, factors such as speed and efficiency, expertise in regulatory compliance, and transparent fund administration should be considered. Thus, utilizing the right private placement escrow agent ensures that the escrow process complies with the statutory requirements of private placements and provides all parties involved the necessary peace of mind.
Opting for a trust company for escrow services in private placements offers the advantage of enhanced independent oversight. Using a licensed fiduciary increases investor confidence and ensures a higher standard of compliance and security in managing substantial financial transactions involved in private equity and private offerings.
Broker-dealers are mandated under SEC Regulation Best Interest (Reg BI) and FINRA Rule 2111 (Suitability) to investigate the security when recommending it thoroughly. By doing so, the broker-dealers ensure they understand the risks and rewards associated with the private placement offerings and have a reasonable basis to believe that the recommendation is in the best interest of retail customers. Thus, the SEC’s Regulation Best Interest (Reg BI) extends to all recommendations to retail customers involving securities transactions or investment strategies, including Reg D, Reg A, Reg A+, Reg CF (Crowdfunding), or Reg S offerings private placement offerings.
FINRA Rules 5122 and 5123 stipulate that member firms (broker-dealers) must file offering documents and information for private placement offerings they sell with FINRA’s Corporate Financing Department promptly.
Rule 15c2-4 governs the handling of funds by broker-dealers during contingency offerings. It mandates that funds must either be placed in escrow with a bank or deposited in a segregated bank account, where the broker-dealer acts as trustee or agent. This rule protects investors by ensuring that offering proceeds are only transferred or under the offeror’s control upon fulfilling the required contingencies.
When selecting a private placement escrow agent, choosing an impartial and independent agent with expertise in private placement escrow services is crucial. The escrow agent should use market-accepted agreements and terms and comply with Know Your Client (KYC), anti-money laundering (AML), taxation, and other legal requirements. By doing so, the escrow agent assists in safeguarding that the escrow process complies with all associated statutes and regulations.
Engaging an escrow agent early in the capital raise process is crucial for presenting a well-prepared pitch to potential investors. Proactively selecting your escrow agent while creating the investor presentation can assist in maximizing investor confidence and credibility.
Selecting the right escrow agent is a pivotal decision in the private placement process. Speed, efficiency, expertise in regulatory compliance, and effective fund administration ensure the escrow process aligns with the applicable regulatory requirements of private placements. The culminating insight from this examination underscores the significance of escrow accounts in providing a secure, regulated structure that supports the intricate dynamics of private placements, fostering a trustful investment environment. This understanding points to further avenues for discussion and research, particularly in optimizing these financial instruments for future transactions and developments within the sector.
The advantages of using a licensed vendor (such as a trust company) over a traditional bank account are measurable. The provision of active independent oversight by a trust company adds a significant layer of security and integrity to these financial transactions, directly contributing to heightened investor confidence.
The crucial aspect of investor confidence is the linchpin in successfully offering private placements. Private Placement Escrow Accounts safeguard investor assets and streamline the “Breaking Escrow” transaction process under the applicable regulatory framework - thus ensuring all party’s satisfaction.
Additionally, you can open an account on platforms like Eastern Point Trust Company.
Avoid Massachusetts's taxation on Qualified Settlement Funds (QSF) income. Always establish a QSF in other jurisdictions to reduce QSF tax liabilities.
Massachusetts is known for Boston, Cape Cod, the Salem Witch Trials, and high taxes. It is no surprise that, when creating a Qualified Settlement Fund (“QSF”) in Massachusetts, the state imposes its aggressive tax policy on QSF income. Therefore, any QSFs used in Massachusetts or established by Massachusetts’ governmental authorities are subject to federal and Massachusetts taxation.
Massachusetts’ applicable income tax rate for the 2023 tax year is a flat five percent (5%) rate on the entirety of the QSFs’ taxable income. As of 2023, an additional 4% tax income over $1 million also applies. Thus, the Massachusetts Department of Revenue’s Letter Ruling 08-7 demonstrates that creating a QSF in Massachusetts is a costly mistake that will result in unnecessarily high taxation.
In Letter Ruling 08-7, issued March 28, 2008, the Massachusetts Department of Revenue established Massachusetts’s position concerning the “Taxation of Qualified Settlement Fund.”
The Massachusetts Department of Revenue ruling outlined the following:
While a few states have higher taxes than Massachusetts’s top rate of nine percent (9%), many states have no taxation to a trust-based QSF. Thus, planners and attorneys should carefully consider in which jurisdiction you create a QSF and judge the advantages of QSF 360 to tax optimize and reduce your QSF tax liabilities.
Discover the strong privacy protections and effective shields offered by Qualified Settlement Funds (QSFs) against discovery demands. Learn about QSF 360 platform's innovative privacy and protection features.
§468B Qualified Settlement Funds (QSFs) are tax-qualified legal entities that are useful to settle single-event, mass torts, and class action lawsuits and allow the consolidation of multiple “related” claims into a single fund. The establishment and operation of QSFs governed by 26 C.F.R. §1.468B-1, et seq.
Ensuring the privacy and security of a Qualified Settlement Fund and its information is crucial. In the case of a pre-funded Qualified Settlement Fund, safeguarding sensitive information to prevent unauthorized or adverse party access protects the defendant’s privacy and the integrity of the funds. The privacy provisions of a QSF and its existence as a separate legal entity can hinder adverse parties from inflating their claims based on knowledge of the QSF’s available assets.
Further, a properly designed and drafted §468B Qualified Settlement Fund can provide valuable “discovery limitations.” Maximizing these advantages requires an experienced and steadfast QSF trustee who will vigorously assert the associated privacy and limitation powers to suppress undesirable litigation discovery.
In some cases, defendants have apprehension regarding the question of privacy or discoverability of Qualified Settlement Fund details by adverse parties. In particular, when a defendant(s) utilizes a pre-funded QSF to address multiple current and future claims, there can be concerns (albeit largely unfounded) regarding whether a plaintiff may acquire information related to the defendant’s identity or knowledge regarding the existence of a QSF and its level of funding by searching a public source or by discovery through a subpoena.
Unlike other entities whose information is readily available through searchable databases, in the case of QSF, there are no such public sources or databases. Accordingly, no government database searches are even possible. As such, adverse parties have no likely chance of discovering a Qualified Settlement Fund’s existence or the identity of a defendant associated with it.
Even if the existence of a QSF becomes known, with a properly drafted QSF, the trustee has many practical tools to quash discovery inquiries.
Pro Tip: Having a trustee who is a vigorous advocate in defending the privacy of the QSF is a critical element in protecting the QSF.
Pro Tip: Having a trustee who maintains a robust and comprehensive privacy policy that would apply to any third parties making a claim on the QSF or serving a demand for discovery is indispensable in protecting the privacy of a QSF. Non-trustee QSF administrators may have no enforceable privacy policy protections for the QSFs they administer as non-trustees.
QSFs maintain privacy by ensuring the fund’s existence and claimants’ identities remain sealed and confidential. This confidentiality is crucial in sensitive legal matters, protecting the individuals involved from unwanted exposure. To safeguard the anonymity of the parties and the financial condition of the QSF, the trustee plays a vital defensive role in protecting information from prying adverse parties. The trustee may employ various tactics by challenging all requests, imposing legal barriers, decanting, applying jurisdiction selection requirements, and utilizing the courts to avoid subpoenas or quash.
As mentioned, in a properly drafted QSF, the trustee will have the necessary power to employ decanting, situs-shifting, and other trustee-power tactics to protect the parties’ privacy and defeat discovery fishing expeditions.
QSF transactions and records are not part of public records, and the IRS is prohibited from disclosing tax returns based on a civil subpoena. This integrated approach helps prevent access to private information related to the QSF. Here again, we see that privacy provisions in an adequately designed QSF can protect the privacy of all documents and information associated with QSFs. The Courts are highly reluctant to allow the breach of all Claimant’s privacy solely for a fishing expedition inquiry associated with an unrelated matter.
Qualified Settlement Funds offer strong privacy protections and can be effective shields from discovery demands. The QSF 360 platform provides the QSF industry with innovative and robust privacy and protection from discoverability.
A comprehensive overview of naming conventions for Qualified Settlement Funds (QSFs), including length restrictions, statutory requirements, and safe harbor options to ensure compliance and avoid misleading or deceptive naming.
Qualified Settlement Funds (QSFs) are valuable statutory-based financial mechanisms that offer tax benefits and flexibility in managing settlements and the associated settlement administration across various disputes and litigation.
Established under 26 USC §468B and 26 CFR §1.468B-1 et seq., defendants can “transfer” settlement obligations, claim the associated tax deductions immediately, and facilitate the tax-efficient disbursement of funds to the claimant(s).
Here, we explore the proper naming conventions for a Qualified Settlement Fund name, highlighting the key considerations and appropriate naming conventions to support the fund’s integrity and purpose.
Pro Tip: For more information on QSFs, how to create, their benefits, and how they work, see the following links
The naming conventions in QSFs are not merely a formality but a necessity. It is important to note that, in addition to the statutory requirements for QSFs. Therefore, let’s do an overview of QSF naming guidelines and statutory requirements:
A governmental authority must approve and exercise jurisdiction over a potential QSF for it to become a QSF. That authorizing governmental authority will have its own policies and requirements for QSF naming conventions. Among other things, these policies ensure that the name of a QSF is not intentionally (or unintentionally) misleading.
Generally, state and federal law prohibits any entity from being deceptively named. For example, you may not name a trust using the term “Inc.” in an attempt to misrepresent the trust as a corporation. Also, state statutes prohibit naming a sole proprietorship using the term “LLC” to imply it is a Limited Liability Company when it is not.
Moreover, it is crucial to note that a QSF is not an Interest on Lawyers Trust Account (“IOLTA”) nor an account owned by a law firm; thus, no QSF should be labeled to imply that it is. Severe ethical consequences could result. Therefore, it is prudent never to use a name for a QSF that would give the impression that the QSF is an IOLTA or a law firm’s corporate bank account.
Noted QSF commentator Robert Wood, in his article Qualified Settlement Funds Named Like Lawyer Trust Accounts, while discussing the flexibility available in naming a QSF also raises the concern of possible ethical or bad faith issues surrounding the use of a misleading or deceptive QSF name.
The following provides roadmap examples of QSF names that work and others that may likely cause issues:
Generally speaking, there are safe harbors when naming a QSF:
If a law firm uses, or plans to use, several QSFs, then standardizing naming conventions allows more effective case management and quicker access to essential documents. A consistent naming convention also improves transparency and avoids confusion for audits, legal reviews, and timely and accurate distribution of funds.
Avoiding misleading or deceptive naming conventions when naming a QSF is crucial. The name should not misrepresent the nature of the fund or its ownership, as this could lead to confusion or legal and ethical challenges.
Pro Tip: See the related article regarding Who Owns a QSF.
Avoid overly complex or obtuse names for a QSF. Names that are difficult to understand or remember can hamper communication and operations or lead to mistakes. A straightforward and clear name ensures that all parties, including the defense, claimants, and the associated legal and financial professionals, can easily refer to the QSF without confusion or question.
When navigating QSFs, carefully selecting a compliant name is not merely a governmental requirement; it can also remove barriers and eliminate questions. Recognizing common pitfalls and adhering to IRS rules and nondeceptive guidelines in choosing a name can avoid potential ethical conflicts and ensure the fund’s smooth operation.
An in-depth exploration of the common myths and realities surrounding Qualified Settlement Funds (QSFs) and their administration. Dispel misconceptions and highlight the benefits for all parties involved in litigation.
Qualified Settlement Funds (QSFs) are qualified tax entities established under the legal framework of 26 U.S.C. § 468B, regulated under 26 C.F.R. § 1.468B-1, and operate as statutory trusts. These QSFs or Section 468B trusts are settlement funds created upon the approval of a “government authority.” Critical to a successful QSF implementation is the Qualified Settlement Fund Administrator and associated QSF Administration, which streamlines the settlement process for efficient distribution to the involved parties. This consolidation simplifies the fund’s administration and introduces tax benefits designed to empower the plaintiffs financially.
In this article, we will explore the common myths regarding Qualified Settlement Funds and Qualified Settlement Fund Administration.
One common misconception about Qualified Settlement Funds is that they are exclusively utilized for mass tort and class action settlements. However, the versatility and application of QSFs extend far beyond these areas.
Broad Application: QSFs are designed to resolve and satisfy claims, including those made before the QSF is established and funded. This broad application makes them suitable for most types of torts, breach of contract, and environmental liability cases.
Diverse Case Types: The use of QSFs spans a wide range of cases. They are not only applicable in scenarios with large numbers of plaintiffs, such as product-liability cases, drug cases, and sexual abuse cases, but also in single claimant cases.
Ethics and Compliance: Particularly in cases with multiple plaintiffs, QSFs play a crucial role in ensuring compliance with ethics rules.
Uncooperative Defendants: QSFs support structured settlement solutions even when a defendant or insurer is unwilling to enter directly. Moreover, QSFs can effectively pay adverse parties with and without liens and address lien resolutions.
Myth 2: Only Plaintiffs Benefit From QSFs
The myth that only plaintiffs benefit from QSFs overlooks the multiple advantages these funds offer to all parties involved in litigation. The following outlines the benefits for both plaintiffs and defendants, showcasing the unique utility of QSFs:
Deferred Taxation: Plaintiffs benefit from deferring taxes on their settlement amounts until the funds are distributed, providing significant financial planning flexibility.
Flexibility: Plaintiffs gain financial planning and tax benefits by avoiding immediate access to income from the settlement and having ample time for negotiations to address liens and choose distribution methods.
Conflict Resolution: QSFs facilitate the resolution of disputes among multiple plaintiffs and their attorneys, contributing to a more efficient and equitable settlement process.
Settlement Planning: Plaintiff attorneys can secure the settlement proceeds in a QSF, providing a safe space to work out a comprehensive settlement plan, address liens, and engage in probate proceedings without the pressure of immediate distribution.
Immediate Tax Deductions: Defendants can immediately claim tax deductions for their contributions to a QSF, even if the funds have not yet been distributed among the plaintiffs. This benefit to the defendant is particularly significant because it allows for deductions when the settlement is paid into the QSF rather than upon distribution to each plaintiff.
Litigation Closure: By contributing to a QSF, defendants can remove themselves from the ongoing settlement administration process, often receiving a permanent release upon their contribution. Thus, QSFs simplify the settlement process and provide financial and legal closure.
Streamlined Process: Forming a QSF can bridge difficulties when plaintiffs and defendants cannot agree on tax language or reporting, ensuring that all tax, legal fee, and payout issues are managed strictly between plaintiffs and their lawyers outside the influence of defendants.
Contrary to the prevalent belief that establishing a Qualified Settlement Fund (QSF) is a costly affair, platforms like QSF 360 offer the creation of a QSF for a setup fee of only $500. The process and costs associated with setting up and maintaining a QSF are as follows:
The myth surrounding the overwhelming complexity of Qualified Settlement Fund (QSF) administration can deter parties from considering this efficient settlement solution. However, understanding the structured roles and responsibilities can demystify the process:
Dispelling the myth that Qualified Settlement Funds (QSFs) offer limited tax advantages requires an in-depth exploration of the tax benefits they present for defendants and plaintiffs. Here is a concise breakdown:
Immediate Tax Deduction for Defendants: Upon contributing to a QSF, defendants are eligible for an immediate tax deduction, even if the funds have yet to be distributed to the plaintiffs. The upfront deduction can significantly reduce the defendant’s taxable income in the fiscal year of the contribution.
Income Deferral for Plaintiffs: Plaintiffs can defer taxation on their settlement amounts until distribution. The benefit of deferral can offer substantial financial planning advantages, allowing plaintiffs to potentially lower their tax obligations by receiving funds in years when they may be in a lower tax bracket.
Structured Settlements and Legal Fees: Both structured settlements and structured legal fees are available post-defendant involvement, providing plaintiffs and their attorneys the flexibility to plan for future financial needs. Notably, structures, including the attorney fees portion of the claimant proceeds, can circumvent constructive receipt and economic benefit doctrines, taxing plaintiffs and their attorneys only upon receiving each payment.
Separate Tax Entity Status: As a separate tax entity, QSFs are subject to taxation on interest and dividend income at the maximum rate of 39.6% (as of 2024). Despite the taxation, QSFs benefit from deductions for administrative costs, incidental expenses, and losses sustained in property transactions.
Accrual Accounting and Corporate Treatment: QSFs must employ an accrual method of accounting and are treated as corporations for subtitle F of the Internal Revenue Code. This corporate treatment simplifies tax reporting and compliance, ensuring that the tax imposed on the QSF’s modified gross income is treated consistently with corporate tax obligations.
No Explicit Time Limit: The absence of a strict time limit for the existence of a QSF provides flexibility in managing complex cases that may span several years. This enduring nature ensures that all controversies can be resolved without rushing the process, benefiting all parties involved.
The myths surrounding QSFs, QSF Administration, their applicability, costs, tax advantages, and administrative complexity are unfounded. Additionally, the critical element to ensure a seamless QSF is the QSF Administrator.
Particularly noteworthy is the capacity of QSFs to extend beyond limited use scenarios, provide benefits to plaintiffs and defendants, and offer significant tax advantages that can profoundly impact financial planning and legal strategy.
In navigating the complexities and ensuring optimal outcomes within the QSF framework, engaging a skilled and experienced administrator is vital. Use only a licensed fiduciary for QSF Administration to ensure compliance, maximize tax benefits, and streamline the settlement process for all parties involved. This professional insight and management are pivotal in harnessing the full potential of QSFs, transforming them from a misunderstood financial instrument into a powerful solution for dispute resolution and settlement planning.
Discover the harsh reality of punitive damages taxation, how it affects plaintiffs, and solutions to increase after-tax recovery by 50% to 150%. Learn more about reducing taxation on settlement proceeds.
Punitive damages are always fully taxable. This unwelcome and often unknown fact is true when punitive damages are awarded in conjunction with a tax-free compensatory award (e.g., physical injuries or sickness) or a taxable claim (e.g., non-physical injuries, defamation, or another tort).
The taxes you will pay are likely much higher than you think. Under the current tax code, you must pay taxes on the portion of the punitive award you do not even receive – like the attorney’s fees and costs.
Unfortunately, under our tax laws, a person as a plaintiff receiving punitive damages is fully taxed on the punitive portion and is thus treated more punitively than the defendant paying them. This harsh tax reality is because of the odd but real “plaintiff double tax.” 1
The plaintiff’s double tax arises because the plaintiff is taxed on the entire taxable recovery – including the punitive damages – but cannot deduct the attorney fees and costs associated with the recovery. That is because such fees and costs are treated as “miscellaneous itemized deductions” (MIDs), which are not fully deductible.
Here is a realistic example: Joan, living in California, receives $2,000,000 in damages for a physical injury and an additional $10,000,000 in punitive damages. The $2,000,000 isn’t taxed, but the $10,000,000 punitive portion of the settlement is.
Out of the above, Joan owes her attorneys a 40% contingency fee on the punitive portion ($4,000,000). However, she cannot deduct the attorney’s fees for federal or state income tax purposes. Also, her combined Federal and State income tax rate is around 50% since she’s in the top tax bracket. As a result, her “net-net” (after-tax and attorney fees) proceeds on the punitive portion is around $1,000,000 - just 10 cents on the dollar of the total punitive proceeds, and could be even less!
WOW, poor Joan – Regretfully, there are other unpleasant realities Joan shall be surprised to learn:
Talk about punitive! (Other epithets may come to mind.)
In certain limited case types, such as employment and civil rights discrimination, an “above the line” deduction is indeed allowable for attorney’s fees and costs, avoiding the plaintiff’s double tax. However, this deduction rarely applies since punitive damages are infrequently awarded in those cases.
Caution – PRO TIP: Various dubious suggestions haunt the internet and purport to circumvent the plaintiff’s paying taxes on the attorney portion of the taxable recovery. These suspect “tax tricks” are designed to misclassify a portion of the proceeds, including issuing separate Form 1099s for the plaintiff and the attorney or alleging a quasi-partnership arrangement between the plaintiff and the attorney. Thus, take caution; the Supreme Court precluded these approaches in the Commissioner v. Banks Supreme Court decision. Employing such tenuous schemes may open the door to significant tax underpayment penalties and possibly even more severe allegations and actions by the IRS. Also, the above-the-line deduction is plainly shown on the tax return and is a glaring audit signal to the IRS; the larger the deduction, the more likely the audit risk.
Plaintiffs who may receive punitive damages may wish to consider a Plaintiff Recovery Trust (PRT) before the claim becomes final or fully settled. A PRT is a specially designed trust that could increase the after-tax recovery by 50% to 150%, and the PRT does not rely on the “above the line deduction.” However, timely action is necessary, and the PRT must be in place before the matter is finalized, including appeals, so the earlier in the case cycle, the better, and a failure to act promptly could result in unnecessary taxation.
To learn more about PRTs, visit the PRT web page or call (855) 222-7513 to speak with a PRT Expert to see if your case qualifies.
Qualified Settlement Funds (QSF) – Listicle of 12 Things to Know. Learn about their purpose, benefits, eligibility, tax implications, QSF administration, etc.
Qualified Settlement Funds (QSF) – Listicle of 12 Things to Know:
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[7/8/24] Joe Sharpe, ETPC President, explained, “QSFs are powerful financial tools to streamline and manage settlements, especially in complex cases. They provide tax benefits, flexibility, and efficient administration for all parties involved. With platforms like QSF 360™, creating and managing a QSF is quick, easy, and fully compliant. From establishing a QSF to understanding the roles of administrators, tax implications, and investment options, our comprehensive listicle covers all you need to know about these financial mechanisms.”
Learn the advantages of QSFs over other settlement structures, QSF regulatory oversight, and best practices for effective management. Make the most of your settlements with QSFs and ensure a smooth, compliant, and beneficial process.
Eastern Point Trust Company invites legal professionals, plaintiffs, and all interested parties to explore more and discover the transformative potential of QSFs in post-settlement dispute resolution. To read the complete listicle and learn more about the advantages of QSFs, visit https://www.easternpointtrust.com/articles/qualified-settlement-funds-listicle-of-12-things-to-know.
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The co-designer of the Plaintiff Recovery Trust, Lawrence Eisenberg, a tax attorney and founder of Forward Giving, Inc., a 501(c)(3) charity, publishes in Tax Notes an article addressing the double taxation of settlements.
The co-designer of the Plaintiff Recovery Trust, Lawrence Eisenberg, a tax attorney and founder of Forward Giving, Inc., a 501(c)(3) charity, publishes in Tax Notes an article addressing the double taxation of settlements.
[7/16/2024] — In a thought-provoking article published in Tax Notes* Lawrence J. Eisenberg, an experienced tax attorney, describes the perplexing issues affecting individual plaintiffs in litigation recoveries and considers how those issues can be addressed, including by using a charitably-based trust-based solution. The article “The Individual Plaintiff Tax Trap — A Conundrum and a Solution” delves into the intricacies of the taxation of litigation recoveries and addresses methods to mitigate the adverse tax consequences some individual plaintiffs face.
Background
Eisenberg’s article highlights the strange and often inconsistent tax treatment of individual plaintiff litigation recoveries under the Internal Revenue Code. Despite the Supreme Court’s 2005 decision in “Commissioner v. Banks”, which held that plaintiffs must report the entire recovery as taxable income—including the portion payable to attorneys—many plaintiffs (and their attorneys and advisors) remain unaware of the potential tax pitfalls when such recoveries do not fall under tax-free categories, e.g., damages for physical injuries.
The Individual Plaintiff Tax Trap
The crux of the issue lies in the deductibility of attorney’s fees. Some recoveries are tax-free, so attorney fee deductibility is not relevant, or allow for an above-the-line deduction of these fees. Other recoveries can result a “double tax”, because in those situations, the attorney fee portion of the recovery is taxable, but the attorney fee itself is not deductible. This leads to significantly diminished net recoveries. Eisenberg’s article includes a detailed example demonstrating how a plaintiff’s net recovery can be less than 10% of the total amount, with the government and attorneys each receiving several times more than the plaintiff!
A Trust-Based Solution
To address this inequity, Eisenberg proposes that a plaintiff affected by the double tax create a Plaintiff Recovery Trust (PRT). A PRT allows plaintiffs to transfer their litigation claims to a specially designed split-interest charitable trust. By doing so, the litigation claim becomes an asset of the trust, and any recovery is received by the trust, which then pays the net recovery to the trust beneficiaries, including the plaintiff. The PRT uses ordinary trust law principles and aims to achieve fairer tax treatment by separating the ownership of the litigation claim from the individual plaintiff.
Key Benefits of the Plaintiff Recovery Trust
- Equitable Tax Treatment: By treating the litigation claim as a trust asset, a Plaintiff Recovery Trust results in the plaintiff not being taxed on the portion of the recovery paid to their attorneys.
- Structured recovery: The PRT trust structure allows for a more organized and potentially tax-efficient distribution of recoveries. (It also permits the use of structured settlements as part of the solution.)
- Charitable Component: The PRT includes a charitable beneficiary, adding a philanthropic dimension to the solution.
Conclusion
Eisenberg’s article is a call to action for tax professionals and litigation attorneys to recognize and address the unfair tax treatment many individual plaintiffs face. The PRT trust-based solution offers a way to alleviate the financial burden imposed by current tax law, so that plaintiffs retain a fair share of their recoveries.
See the full article on the taxation of settlement proceeds.
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Eastern Point Trust Company is pleased to announce the release of a new guide designed to address the challenging intricacies of post-settlement litigation disputes.
Eastern Point Trust Company Unveils Comprehensive Guide on Navigating Post-Settlement Disputes and Complexities with Qualified Settlement Funds
[5/17/2024] — Eastern Point Trust Company is pleased to announce the release of a new guide designed to address the challenging intricacies of post-settlement litigation disputes. The guide focuses on utilizing Qualified Settlement Funds (QSFs), also known as 468B trusts, as a streamlined solution for efficient settlement fund management and dispute resolution.
It is not uncommon for secondary disputes to arise following a litigation settlement or court award. These disputes can range from family disagreements over their "fair share" to lawyers disputing fee splits, plaintiffs contesting attorney fees, and third-party lien holders emerging to stake claims against the litigation proceeds. Such complexities often hinder the settlement process and prolong the resolution.
Eastern Point Trust Company's newly released guide provides detailed insights into how QSFs can be employed to manage these disputes effectively. By offering a structured approach to fund management and tax compliance and providing the necessary time for informed decision-making, QSFs present a viable solution to post-settlement challenges.
Sam Kott, Vice President of Eastern Point Trust Company, emphasized the significance of the guide, stating, "This guide explores the advantages of QSFs, specifically their ability to address complex issues such as post-settlement disputes, secondary litigation, and lien resolution. The guide also provides direction on navigating post-settlement challenges and highlights the benefits of QSFs in achieving the best possible outcomes for all parties involved."
The guide delves into the various advantages of utilizing QSFs, including:
Eastern Point Trust Company invites legal professionals, plaintiffs, and all interested parties to explore the guide and discover the transformative potential of QSFs in post-settlement dispute resolution. To read the complete guide and learn more about the advantages of QSFs, visit here.
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Eastern Point is proud to announce the release of its latest publication, Unveiling the Complex World of Taxable and Tax-Free Settlements.
Eastern Point is proud to announce the release of its latest publication, Unveiling the Complex World of Taxable and Tax-Free Settlements.
FOR IMMEDIATE RELEASE
[5/17/2024] — Eastern Point is proud to announce the release of its latest publication, Unveiling the Complex World of Taxable and Tax-Free Settlements. This comprehensive guide delves into the intricate workings of taxable and non-taxable settlements, offering invaluable insights into compensatory damages, punitive damages, and the tax treatment of various settlement types.
Ms. Rachel McCrocklin, Eastern Point’s Chief Trust Officer, commented, “The guide provides a detailed understanding of the pivotal role of IRS Section 104 and the taxability of various settlement types. Our goal is to equip readers with the knowledge to make informed decisions and minimize potential tax liabilities.”
The guide explores strategic methods to minimize tax obligations on settlements, including leveraging structured settlement annuities, Plaintiff Recovery Trusts, and proper allocation in settlement agreements. It is an essential resource for individuals and businesses navigating the complex landscape of settlement taxation.
Arm yourself with knowledge, make informed decisions, and minimize potential tax liabilities with Eastern Point's newest guide.
For more information on Unveiling the Complex World of Taxable and Tax-Free Settlements, please visit https://www.easternpointtrust.com/articles/unveiling-tax-free-settlements-what-you-need-to-know or contact 855-222-7513.
CTRO
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A new comprehensive guide has emerged catering to those seeking to conduct private placements. This guide outlines the pivotal role of escrow accounts in private placements, providing a secure, regulated structure that safeguards investor assets and boosts investor confidence.
A new comprehensive guide has emerged catering to those seeking to conduct private placements. This guide outlines the pivotal role of escrow accounts in private placements, providing a secure, regulated structure that safeguards investor assets and boosts investor confidence.
FOR IMMEDIATE RELEASE
[5/2/2024] — A new comprehensive guide has emerged catering to those seeking to conduct private placements. This guide outlines the pivotal role of escrow accounts in private placements, providing a secure, regulated structure that safeguards investor assets and boosts investor confidence.
It reviews the advantages of choosing a trust company over a traditional bank account for escrow services, emphasizing active independent oversight that enhances transaction security and integrity.
Ned Armand, CEO, noted, “The guide also highlights the critical role of an escrow agent in managing funds prudently, ensuring a smooth progression of transactions under the regulatory frameworks.” Offerors of private equity and Reg D, Reg A, Reg A+, Reg CF, and Reg S offerings are encouraged to explore this guide, available on Eastern Point Trust Company.
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In today's dynamic business landscape, where environmental liabilities pose significant challenges, the Qualified Settlement Fund (QSF) emerges as a beacon of efficiency and reliability.
In today's dynamic business landscape, where environmental liabilities pose significant challenges, the Qualified Settlement Fund (QSF) emerges as a beacon of efficiency and reliability. Contrasting against traditional Environmental Remediation Trusts (ERT), Eastern Point’s QSF offers unparalleled advantages, revolutionizing the approach towards environmental liability management.
FOR IMMEDIATE RELEASE
[2/27/2024] — In today's dynamic business landscape, where environmental liabilities pose significant challenges, the Qualified Settlement Fund (QSF) emerges as a beacon of efficiency and reliability. Contrasting against traditional Environmental Remediation Trusts (ERT), Eastern Point’s QSF offers unparalleled advantages, revolutionizing the approach towards environmental liability management.
The Qualified Settlement Fund stands as a testament to expediency, with the capability to be established and funded within a mere business day, a stark contrast to the lengthy processes associated with ERTs. By swiftly assuming environmental liabilities from present and future claims under CERCLA, state, and local law, QSF ensures immediate action and resolution.
One of the most compelling aspects of QSF is its affordability, with establishment costs as low as $500. This cost-effectiveness, coupled with the tax advantages it provides over ERTs, makes QSF an attractive proposition for businesses seeking prudent financial solutions.
Flexibility is another hallmark of QSF, allowing for single-year or multi-year funding without any maximum duration constraints, ensuring adaptability to diverse business needs. Furthermore, the ability to hold real estate expands the horizons of asset management within the fund.
The benefits extend to tax optimization, with QSF accelerating the transferor's tax deduction for funds transferred to the current tax year, thereby enhancing financial planning and efficiency. Moreover, by shifting liability and associated funding transfers irrevocably to the QSF, businesses can streamline their balance sheets, mitigating risks and enhancing transparency.
In addition to these financial advantages, QSF facilitates seamless settlement agreements to capitate and resolve environmental liabilities, assuring regulators and interested parties of the irrevocable availability of funds for amelioration.
The transition to QSF not only eliminates future administrative burdens but also entrusts the fund's administration to a dedicated trustee, relieving businesses of operational complexities and enhancing focus on core activities.
In conclusion, the Qualified Settlement Fund stands as a beacon of innovation in environmental liability management, offering unmatched advantages over traditional Environmental Remediation Trusts. Its expediency, affordability, flexibility, and tax optimization capabilities redefine the landscape, empowering businesses to navigate environmental challenges with confidence and efficiency.
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Eastern Point Trust Company (“EPTC”) announced that it entered into a sponsorship with the National Forest Foundation (“NFF”) to provide grant funding in support of NFF’s mission to restore and enhance our National Forests and Grasslands.
Eastern Point Trust Company Announces Sponsorship Grants to National Forest Foundation
FOR IMMEDIATE RELEASE
[10/13/2022] — Eastern Point Trust Company (“EPTC”) announced that it entered into a sponsorship with the National Forest Foundation (“NFF”) to provide grant funding in support of NFF’s mission to restore and enhance our National Forests and Grasslands.
Working on behalf of the American public, the NFF leads forest conservation efforts and promotes responsible recreation. Its mission is founded on the belief that these lands, and all they provide, are an American treasure and vital to our communities’ health.
Rachel McCrocklin, Eastern Point’s Chief Client Officer, stated, “Eastern Point welcomes the opportunity to partner with the National Forest Foundation in support of its mission to improve and protect our national lands. A portion of Eastern Point’s revenue is dedicated to funding priority reforestation and enhanced wildlife habitat by supporting the National Forest Foundation’s 50 million for Forrest campaign.”
About Eastern Point Trust CompanyWith over three decades of trustee and trust administration experience, Eastern Point is a world leader in trust innovation that provides fiduciary services to individuals, courts, and institutional clients.
Eastern Point has the benefit of practical experience and industry-leading technology, providing services to over 6,000 trusts with more than 20,000 users across the U.S. and internationally.
About The National Forest FoundationThe National Forest Foundation is the leading organization inspiring personal and meaningful connections to our National Forests, the centerpiece of America’s public lands.
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Eastern Point Trust Company (“EPTC”) announced recent successes of the Plaintiff Recovery Trust (“PRT”) solution in solving the Plaintiff Double Tax, which is the unfair result of 2017 legislation that can cut plaintiff recoveries in half.
Eastern Point Trust provides services across the U.S. and internationally.
FOR IMMEDIATE RELEASE
[11/21/2022] — Eastern Point Trust Company (“EPTC”) announced recent successes of the Plaintiff Recovery Trust (“PRT”) solution in solving the Plaintiff Double Tax, which is the unfair result of 2017 legislation that can cut plaintiff recoveries in half.
Glen Armand, Eastern Point’s CEO, expressed, “Eastern Point’s gratitude for the testimonials of Mirena Umizaj, Joseph Di Gangi, Rebekah Reedy Miller, Susan Gleason, Jennifer White, Andy Rubenstein, and Zane Aubert. By utilizing the PRT, you are the catalyst for saving plaintiffs over $30 million of federal and state taxation.”
Mr. Armand also announced Joseph Tombs as Director of Plaintiff Recovery Trusts (PRT). Mr. Armand also noted, “The contributions of Lawrence Eisenberg and Jeremy Babener for partnering on our newest settlement solution.”
Settlement and financial planners and CPAs can learn and access resources on Eastern Point’s PRT Planner Page here: https://www.easternpointtrust.com/plaintiff-recovery-trust-for-planners
About Eastern Point Trust Company
Eastern Point is a world leader in trust innovation that provides fiduciary services to individuals, courts, and institutional clients across the U.S. and internationally.
With over three decades of trustee and trust administration experience, Eastern Point provides the benefits of practical experience, industry-leading technology, and innovation. Eastern Point Trust provides services across the U.S. and internationally.
About The Plaintiff Recovery Trust
The Plaintiff Recovery Trust is the proven solution to increase the amount plaintiffs keep in taxable cases. Without it, plaintiffs are taxed on the settlement proceeds paid to their lawyers. https://www.easternpointtrust.com/plaintiff-recovery-trust
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Qualified Settlement Funds (QSFs) are powerful financial tools to administer settlements, especially in complex matters. Parties involved in disputes contemplated under 1.46B-1 et seq. can effectively manage and benefit from Qualified Settlement Funds’ tax and financial advantages.
Qualified Settlement Funds (QSFs), a 468B trust, are valuable and crucial in managing litigation settlements efficiently and effectively. "QSF", which stands for "Qualified Settlement Fund", is a fund established as a trust or account established to hold settlement proceeds from litigation. According to the definition under Treasury Regulations, it is an escrow account, trust, or fund established according to an order of or approved by a government authority to resolve or satisfy claims.
This comprehensive infographic guide explains the essential aspects of Qualified Settlement Funds:
The guide provides valuable insights, tips, and rules of thumb for legal professionals, claimants, and other stakeholders about how a QSF account benefits the settlement process. A QSF offers many advantages, including immediate tax deduction for defendants, tax deferral for claimants, and efficient management of settlement proceeds. QSFs are commonly used in class action lawsuits, mass tort litigation, and cases with multiple claimants, but can also provide benefits in single claimant cases.
Setting up a QSF involves petitioning a government authority and appointing a QSF Administrator to oversee the fund. The QSF Administrator, often a platform like QSF 360, is responsible for obtaining an EIN, handling tax reporting, overseeing QSF administration, and making distributions to claimants. Online QSF portals streamline the Qualified Settlement Fund administration process.
Partnering with an experienced QSF Administrator is essential. Services like QSF 360 from specialize in QSFs for both large and small cases and can help ensure compliance with IRC § 1.468B-1 and other regulations.
In summary, Qualified Settlement Funds are a powerful tool for managing settlement proceeds. With proper planning and administration, QSFs provide significant tax benefits, enable efficient distribution of litigation proceeds, and help bring litigation closure. Understanding what is QSF and how to leverage QSFs is invaluable for any legal professional involved in today's settlements.
Eastern Point Trust Company se complace en ofrecer a los clientes de habla hispana un número gratuito exclusivo, así como acceso a un equipo de servicios al cliente compuesto por personal hispanohablante nativo profesional y de alto nivel.
Para obtener más información, comuníquese con el equipo al (855) 412-5100, esperamos trabajar con usted.
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