On this weeks Speaking of Settlements, the weekly podcast feature of
The Settlement Channel, I am joined once again by noted tax law
attorney Robert Wood of the firm Wood & Porter of San Francisco,
CA. The reason for having Rob back two weeks in a row is the news that
the Treasury has issued final regulations on section 468B-6 trusts and
I wanted to get copies and material to my audience as soon as possible.
Now, before anyone gets too excited, these regulations and
final rules are NOT related to the more commonly discussed 468B trust
that is used for litigation and mass torts. These rules are not related
to those trusts or the pending issue before Treasury regarding the
taxation of single claimant structures, as much as we would like to get
that ruling after all these years of waiting.
podcast is relative to the section of those trusts that govern a
variety of other trusts, but specifically those related to section 1031
exchanges and the trust accounts used to manage those transactions.
Now, before you go away and don't read this, keep in mind that Allstate
Life has their structured sale product, which is a vital element of the
1031 fall back or fall out market so knowledge of these provisions is
of keen interest if you are involved in that market.
I know it's a small niche as of yet, but a lot more producers should be looking at the 1031 fallback or fall out market as a means of getting into the structured sales arena. So take a few minutes, click on this link, and learn a little more about 468B-6 trusts and the new rules on section 1031 exchanges.You can also read more on these regulations and obtain a copy of this ruling by going over to The Tax Law Channel and looking for the pdf copy of the regulations.