A 60-minute live webinar — 1.0 hour CA Bar General Credit (MCLE Pending). Hosted by Hans Goldstein, California Insurance Producer NPN 20602398.
Five-million-dollar fee. Take it all in one tax year. Top of the bracket — 37% federal, 13.3% California, 3.8% NIIT. About $2.7 million to the IRS in a single Form 1040.
You don't have to take it all in one year.
An IRC §453 structured installment sale — funded through a non-qualified assignment to a commercial annuity carrier — lets you receive the fee, and recognize the income, over 10 to 30 years on a schedule you choose. The structure must be placed before the settlement or judgment is paid. The window is short. The mechanics aren't taught in CLE.
We'll cover the structure end-to-end, with real numbers and the exact placement language for the retainer or settlement agreement. No solicitation; education only.
Who this is for
Plaintiff-side trial attorneys with a contingency-fee event of $1 million or more — coming, in settlement, or recently paid (some structures still work post-receipt within limits).
What you'll leave with
When §453 is the right move — and when a 1031 exchange or doing nothing actually wins.
The exact placement language for the retainer / settlement agreement.
The non-qualified assignment carriers, their ratings, and how the assignee sits in the structure.
One worked example on a $5M fee you can show your CPA tomorrow.
Hans Goldstein · California-licensed insurance producer (NPN 20602398) · Goldstein & Company, Southern California. Structures attorney-fee deferrals and §453 installment sales on appreciated real estate. Sole focus on plaintiff-side tax structuring for the past several years.
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