Defining Qualified Business Income In Life Settlement Industry

Atlanta lawyers Brian Casey and Tom Sherman and San Francisco lawyer Jaremi Chilton co-authored an article on Internal Revenue Service’s proposed regulations for implementing Code Section 199A of the Tax Cuts and Jobs Acts (TCJA) which includes a 20 percent deduction from taxable (not gross) income for “qualified business income” derived from the direct performance of certain types of professional services or that flow through from fiscally transparent entities. The authors note this code section is good news for insurance agents and brokers and work to define whether that good news carries over to participants in the life settlement industry, the secondary life insurance policy investment and trading business.

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