Fazio National

Settlement Consulting

Tax Resources

Section 104(a)(2) of the Internal Revenue Code excludes from an injured person’s income tax damage amounts paid as part of suit or agreement to resolve physical injury or sickness claims.

Revenue Rulings 79-220 and 79-313 allow injured people to exclude the future value of payments (including increasing payments) and not simply the cost to fund them, also called the "present value," from income tax.

If you're injured future payments are income tax free.

LITIGATION

Fee and commission based professionals are able to defer income without the contribution limits inherent in 401k, SEP or other qualified plans.

Section 409A of the Internal Revenue Code includes rules applicable to certain arrangements associated with what the IRS calls "nonqualified deferred compensation."

The term nonqualified deferred compensation plan means any plan that provides for the deferral of compensation. The application of § 409A is not limited to arrangements between an employer and an employee.

TRANSACTIONS

DISCLAIMER: Informational purposes only. Not tax or legal advice. Parties interested in the programs described are encouraged to consult with thier own tax and/or legal counsel. 


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