Reducing Marginal Tax Rates

A plaintiff’s counsel retained me to assist in structuring the settlement of a very senior executive whose severance package was worth over $17,000,000. By coordinating a move to a tax jurisdiction which did not tax offshore income and structuring part of the settlement as retirement compensation arrangement funding for a previously unfunded supplemental executive retirement plan, the plaintiff’s marginal tax rate in respect of over $11,000,000 of the severance was reduced from 53% to 15%, saving over $4,000,000 in taxes.