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Structured Settlement Blog

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Structured Settlement Factoring Guide Updated

The Guide to the Transfer of Structured Settlements Annuities has been updated by the National Association of Women Judges. See the news release http://www.primenewswire.com/newsroom/news.html?d=131589 for more information. It was written by two judges along with an executive of J.G. Wentworth, a factoring company. J.G. Wentworth is listed as a “Gold…

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Attorney Fees and Private Annuity Rules

In their article entitled “Attorney Fees and Private Annuity Rules” TAX NOTES, January 22, 2007, http://papers.ssrn.com/sol3/papers.cfm?abstract_id=958185 Messrs. Raby and Raby embark on an intriguing discussion on this topic and argue that deferred attorney fees fit under the private annuity rules. On page 311, item 4. they state that, “We believe…

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Executive Life Policyholders get $295 million distribution

Former Executive Life Insurance Company policyholders who “opted in” will share $295 million in addtional distributions from an arbitration award. This resulted from a dispute being resolved between the National Organization of Life & Health Guarantee Associations and the California Department of Insurance. See the full press release from the…

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468B Single Claimant Guidance Request on Treasury’s 2006 Priority Plan.

The Treasury Department has announced that the Society of Settlement Planner’s request to clarify section 468B’s tax treatment of a single-claimant qualified settlement fund is on their 2006 Priority Guidance Plan. In its August 15, 2006 joint statement it stated that the 264 projects should be completed between June 2006…

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John McCulloch leaves Allstate for EPS

Allstate Life Insurance Company announced today that John McCulloch, the manager of Structured Settlements at Allstate, has accepted the position of Vice President of Marketing for EPS Settlements.  This move is effective September 16, 2006.  Ron Johnson, Assistant Vice President of Allstate Life Insurance Company will take over managing the…

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Murphy v. IRS: IRC 104(a)(2) nonphysical damages are excludable (Overturned but interesting reasoning)

Murphy v. I.R.S. — F.3d — 2006 WL 24113372, D.C.Cir., Aug 22, 2006 (Slip Opinion No. 05-5139). Quick summary What the Murphy court said is if you are emotionally harmed or if your reputation is injured, you get to keep all of the damages and not pay any taxes. [Please…

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