Firmwide Qualified Settlement Funds – What Can Go Wrong? (Part 1 of 2)
An analysis of the use of FWQSFs and the implications of PLR 201833012 and PLR 9549026, along with other IRS comments, in meeting the related claims requirement under section 1.468B-1(c)(2). This analysis sheds light on the potential challenges and limitations of FWQSFs.