- Alternative for lump-sum fee payments
- You may choose to structure some or all of your fee
- Attorney receives periodic payments set over a period of time
- Unlike the clients annuity, it is tax deferred and not tax free
- Deferred income may lower your tax bracket
- Attorney’s taxed as payments are received
- 1994 court decision in (Richard A. Childs, et al., v Commissioner of Internal Revenue) set legal precedent for attorney fee structuring
- Steps and rules set forth by issuing life companies must be followed carefully to avoid possible tax issues
