Dr. Pettingill prepares present value analyses of structured settlement proposals using current annuity rates and Treasury yields, with the tax treatment documented per Section 451 and Section 104(a)(2).
Methodology
IRS 451 Structured Settlements (2026)
Current-year application of Section 451 to structured settlements.
Frequently Asked
Frequently Asked
What is the implicit discount rate in an offer?
It is the rate that equates the offered periodic payment stream to the cost of the underlying annuity. Comparing it to current Treasury yields shows the spread the offering party is earning on the structure.
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