Structuring Life Settlements Investment Funds After TCJA

By Brian Casey, Thomas Sherman and Jaremi Chilton (May 3, 2018, 3:49 PM EDT) -- This is the second of our three part series of articles regarding the key impacts of the recent federal tax legislative reform now commonly known as the Tax Cuts and Jobs Act on the U.S. life settlements industry. Read the first part, discussing new reporting rules for life settlement transactions, here. This article focuses on the TCJA's changes affecting life settlements investment fund tax structuring.

The TCJA has ushered in many important changes to the federal income taxation of various types of U.S.-based business entities as well as for U.S. resident individual taxpayers. Before the TCJA, certain offshore life settlements investment...

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