Tax Reduction and Deferral Strategies for Trial Attorneys – Part 3

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.