David Shechtman and Matt Meltzer recently prepared an “FAQ” memorandum for the 1,200 members of the National Structured Settlement Trade Association (“NSSTA”) analyzing the IRS’s recent “general legal advice memorandum” (GLAM) on arrangements used by plaintiff’s lawyers to defer taxation of contingent legal fees.
The memorandum concludes that the GLAM’s skepticism regarding an arrangement modeled on other deferred compensation plans should not jeopardize the longstanding tax treatment of traditional attorney fee structures using assignment companies. Founded in 1985, NSSTA represents consultants, brokers, attorneys, insurance companies, and other professionals who work to settle claims of accident survivors and their dependents. The memorandum is attached below and available on NSSTA’s website here.
Matt and David are also working with the NSSTA to promote tax-free treatment for settlements of post-traumatic stress disorder claims.