Trial attorney - Tax Planning Using PPLI and CLATs (Supplemental Presentation)

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Part I of this series focused on tax reduction and deferral strategies for trial attorneys with contingent fee income using private placement variable deferred annuities in lieu of fixed annuities for structured settlement payments. Part 2 of this series focused on the use of closely held insurance companies (aka captive insurance arrangements) to provide tax reduction and deferral of contingency fee income. In Part 2, the captive insurer can function as a multi-line insurer (property and casualty as well as life insurance) and issue the structured settlement annuities for contingency fee deferrals referenced in Part I of this series.

The latest installment uses a split interest charitable trust – a charitable lead annuity trust (CLAT) with a few “bells and whistles” to reduce taxable income from a contingency fee along with providing tax deferral and future estate tax savings. At the same time, the CLAT provides important philanthropic benefits for the underlying charitable causes of the trial attorney. The structure also provides a mechanism to provide current income from the CLAT corpus.

Please see supplemental presentation below for more information.

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Tax

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Gerald Nowotny, Law Office of Gerald R. Nowotny | Attorney Advertising

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