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Understanding Childs: The Cornerstone of Structured Attorney Fee Deferrals

I. Introduction As the IRS’s attorney fee deferral enforcement campaign gathers national attention, legal and tax professionals are revisiting the foundations of fee deferral jurisprudence. At the heart of this discussion stands Childs v. Commissioner, 103 T.C. 634 (1994), aff’d, 89 F.3d 856 (11th Cir. 1996), the seminal Tax Court case that validated the deferral...

To Fee of Not to Fee? The IRS Attorney Fee Deferral Campaign

Introduction In December 2024, the IRS announced a new national enforcement campaign targeting attorney fee deferral arrangements. The resulting uncertainty raised serious questions within the legal and settlement planning communities: Does the campaign challenge all fee deferrals,  or only those that deviate from long-standing precedent? Originally published in Tax Notes on June 9, 2025, this article...

Independent Life Launches iStructure Select: A New Era in Structured Settlement Solutions

FORT WORTH, Texas, June 17, 2025 /– Independent Life Insurance Company, the only provider focused exclusively on structured settlements, is proud to announce the official launch of iStructure Select, an innovative, index-linked structured settlement annuity, designed to meet the evolving needs of plaintiffs and their attorneys. Created for those seeking more control, higher growth potential, and lifelong security,...

iStructure Select: A New Era of Innovation in Structured Settlements

Every once in a while, a new product redefines what’s possible – not by following trends, but by setting them. That’s the spirit behind iStructure Select, Independent Life’s next-generation structured settlement solution. We’re not releasing all the details just yet. But here’s what we can tell you: this is not just a new product. It’s...

Independent Life to Launch iStructure Select: A Game-Changing Innovation in Structured Settlements

FORT WORTH, Texas, June 2, 2025 — Independent Life Insurance Company, the first and only insurer dedicated exclusively to the structured settlement market, is preparing to launch its most anticipated product to date: iStructure Select. Set to officially debut this summer, iStructure Select represents a bold evolution in plaintiff-focused financial planning. Designed with innovation at its...

Structured Installment Sales: Unlocking Opportunity and Tax Efficiency Through Annuity-Funded Transactions

The Structured Installment Sale (SIS) has emerged as an innovative and practical solution for tax deferral and income security in the sale of appreciated assets—particularly in the business and real estate sectors. For sellers seeking to manage the tax impact of capital gains and create predictable future income, SIS transactions offer a unique blend of...