Significant Tax Statutes

• Article XVI , United States Constitution
  • Power of Congress to tax
• IRC Section 461
  • General rule for taxable year of deduction
• IRC Section 461 (h)
  • Economic performance requirement (timing of expense/deduction)
• IRC Section 104,
  • Compensation received on account of personal physical injury is not taxed
• IRC Section 130,
  • Defendants may assign their future obligations to a third party
• IRC Section 468b
  • Special rules for designated settlement funds
• IRC Section 5891
  • Structured settlement factoring transactions (sale of SS payments)
• IRS Section 409 Guidance
  • Deferred compensation not applying to services provided to clients by an attorney