Independent review hub for every carrier offering Structured Installment Sale (IRC §453) and Attorney Fee Structured Settlement (IRC §104, Childs v. Commissioner) annuities. A++ / A+ rated only — these contracts last 20-30 years and demand top carriers.
A Structured Installment Sale or attorney fee deferral creates a 20-30 year payment obligation from the funding carrier to the seller/attorney. You're not just buying a product — you're locking in a multi-decade credit relationship.
For these contracts, only the strongest US life insurance carriers are appropriate:
Send me the sale price and rough basis and I'll email you the actual number within one business day — plus the Seller's Guide to §453. If it doesn't fit your deal, I'll tell you that plainly.
No retainer · no obligation · the carrier compensates the broker, not you.
Best for: standard §453 installment sales + attorney fee deferrals, $250K-$5M deal size. Strong specialty SIS desk, fast turnaround on quotes, competitive payout factors.
Tradeoff: Pacific Life's general-account brand premium means slightly lower payouts than Berkshire Hathaway. Worth it for the brand stability + faster underwriting.
Best for: the largest deals ($500K+ to $10M+), highest credit certainty buyers, attorneys who want absolute top-tier carrier strength.
Backed by Berkshire Hathaway — one of only a handful of A++ rated carriers in the world. The Buffett name carries unique gravitas for seller acceptance + spouse comfort. Slightly lower payouts than mid-tier A+ carriers (you pay for the brand) but the credit certainty is unmatched.
Best for: non-qualified attorney fee structures, complex case design, hybrid §453 + period-certain structures. Independent Life is one of the few carriers built specifically for the SIS + attorney fee niche.
Tradeoff: A− rating is one step below the top tier — for deals above guaranty fund limits, this matters. Get a side-by-side with Pacific Life or Berkshire before committing.
Best for: deals involving military veteran sellers (USAA brand resonates), $250K-$3M range. A++ rating + mutual structure.
USAA's specialty SIS desk is smaller than Pacific Life or Berkshire — turnaround can be slower. Best when carrier brand fit matters (veteran seller).
Best for: legacy contracts (existing an A-rated Fortune 500 insurance carrier SIS sellers). New issuance has wound down — an A-rated Fortune 500 insurance carrier/Brighthouse no longer actively writing new §453 business in most markets.
Tradeoff: A rating (one step below A+ Pacific Life). For new SIS deals in 2026, Pacific Life or Berkshire are stronger choices. Use only if your case has specific legacy structure reasons.
Best for: non-qualified attorney fee deferrals + smaller SIS cases. Mutual of Omaha's SIS desk is solid but not as deep as Pacific Life or Berkshire.
Demand a side-by-side payout comparison from at least 3 carriers for any §453 or attorney fee deal. Critical comparison points:
Under Childs v. Commissioner (1996 Tax Court) + IRC §104(a)(2), plaintiff attorneys can defer fees from §104 personal injury settlements via a structured annuity. The tax deferral is identical to the structured settlement itself — fees aren't constructively received until paid.
For attorney fee structures specifically, the recommended carriers are Pacific Life, Berkshire Hathaway, and Independent Life. USAA + Mutual of Omaha will write attorney fees in some cases but with less specialty desk depth.
Yes — and for deals above $500K, splitting across 2 carriers is often recommended for credit diversification. Pacific Life + Berkshire Hathaway is a common combination.
For deals under $250K (state guaranty fund coverage), carrier rating matters less. For deals $500K+, A++ Berkshire Hathaway provides absolute top-tier credit certainty. For $1M+, multi-carrier diversification is standard.
Both use the same carrier annuity products. The IRS tax treatment differs: §104 (personal injury settlements) provides full income tax exclusion on principal + interest; §453 (installment sales of business/property) provides capital gains deferral as payments are received. Same carriers, different tax sections.