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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...

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...

Let’s Talk About: Judges, Mediators and Settlement Planning

Judges and mediators play important, but distinctive, roles in settlement planning. So it may have surprised some attendees that a recent Society of Settlement Planners (SSP) 2021 Annual Conference virtual presentation advertised as the “Judiciary Panel: Planning from the Court’s Perspective” featured two mediators (one a retired judge) and focused on mediation not judicial issues. Skillfully moderated...

Let’s Talk About: Adding Value & Protecting an Attorney’s Practice

One of the more intriguing panel discussions scheduled later this week during the Society of Settlement Planners’ (SSP) 2021 Annual Conference will feature Paul Isaac, Jeremy Babener, Jack Meligan and Jason Lazarus in a Breakout Session titled: “Adding Value: Protecting the Attorney’s Practice.” Anticipating this panel of settlement planning experts, we thought the perspective of a structured...

Let’s Talk About: Structuring Attorney Fees

Plaintiff attorneys are continuing to gain an understanding of the benefits of structuring their attorney fees, a unique tool, solely available to their profession, that offers an exclusive and excellent way to enhance financial security, both now and in the future. Structured attorney fees, which can defer taxes on contingency fees, allow plaintiff attorneys to...

Free Download: Attorney Fee Checklist

Attorney Fee Checklist Plaintiff attorneys, this blog post is for you. You take care of your clients, but who’s taking care of your business? Believe it or not, a structured settlement can actually help both you and your client. Attorneys may think of structured settlements as an outdated or unfamiliar settlement technique and most plaintiffs’...