Summary

Structured Sales - Installment Sales with Reinvestment into A Rated Investments 

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  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).

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