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Settlement Fund Qualifications and Related Tax Issues Described in Private Rulings  


Author:  Staff Editors.


Source: Volume 23, Number 04, Summer 2006 , pp.375-382(8)




Journal of Taxation of Investments

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Abstract: 

The majority of qualified settlement fund rulings under Reg. 1.468B-1 have concerned class action litigation, often environmentally related. With the collapse of Enron and financial services entities, however, the regulation is more often being interpreted in a different context. Two recent rulings indicate some of the issues that the Service is encountering. Fortunately, it appears that the Service is willing to take a practical and flexible approach to the issues, which is appropriate given the limited resources that are often available for the victims of these scandals.

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