How Plaintiff Lawyer Tax Deferrals Can Get IRS’ GLAM Treatment
Plaintiff attorneys have correctly deferred tax on contingent fees—securing the tax positive aspects of an uncapped 401(k) with a pre-scheduled payout—since the IRS missing its challenge to a rate deferral arrangement in Childs v. Commissioner in 1994. Given that then, the IRS has cited Childs with acceptance, but some arrangements above the several years have…