(Click for Documents)

1. Summary  - Overview of how proceeds of appreciated asset are reinvested immediately into A rated (or other approved investments) directly from escrow.  Sellers defer tax and avoid investment risk and repayment risk and receive ongoing, predictable level of cashflow. 
    

2. Underwriting - Ideal Client- Ideal seller wants to defer taxes, avoid reinvestment risk and does not need a lump sum immediately.  Typically retiring or very high net worth sellers.
    

3. Statutory definition of Constructive Receipt - Taxpayers are taxed when they have construcive receipt of income.  Structured sales are designed to defer tax while providing security of funds.
    

4. Top 100 Cases on Constructive Receipt Doctrine - A comprehensive summary of 100 cases on the constructive receipt doctrine by University of Florida professor.  
    

5. Overview of Structured Settlements - This structured is based on structured settlement law, a longstanding method for lottery winners, injury victims and plaintiff attorneys to defer recognition of lump sum payments.  (Wikipedia article).

​