Structured Installment Sales for High-Net-Worth Divorce Settlements
Structured Installment Sales for High-Net-Worth Divorce Settlements
Dividing wealth in a high-net-worth divorce is never simple—especially when large assets, tax exposure, and cash flow are on the line.
Structured installment sales offer an elegant solution: spreading payments over time to manage taxes, preserve liquidity, and create predictability.
This guide walks through how these structures work and when they can benefit divorcing individuals and their advisors.
📌 Table of Contents
- What Is a Structured Installment Sale?
- Why Use It in a Divorce Settlement?
- Key Tax and Cash Flow Advantages
- IRS Rules and Compliance Factors
- Legal Setup and Settlement Planning
What Is a Structured Installment Sale?
A structured installment sale allows a divorcing spouse to receive payments for marital assets over time—rather than in a single lump sum.
This structure can involve real estate, business shares, or large investment accounts.
It’s often backed by an annuity or third-party assignment company that guarantees payment.
Why Use It in a Divorce Settlement?
Structured settlements help preserve liquidity for the paying spouse, while offering predictable income to the recipient.
They reduce immediate tax burdens and can prevent forced liquidation of key assets like private companies or illiquid investments.
Courts and mediators increasingly favor structured payouts for their fairness and long-term stability.
Key Tax and Cash Flow Advantages
✔️ Tax Deferral: Income is taxed as received, not upfront, easing annual tax liability.
✔️ Capital Gains Management: Helps avoid triggering full capital gains at transfer.
✔️ Cash Flow Control: Spreads large obligations over a schedule aligned with liquidity events (e.g. investment returns).
IRS Rules and Compliance Factors
The IRS requires that installment sales meet specific criteria to qualify for deferral under Section 453 of the IRC.
Structured sales used in divorce must ensure clear documentation of payment schedules, valuation of assets, and fair market consideration.
Improperly structured plans may trigger audits or loss of deferral treatment.
Legal Setup and Settlement Planning
It’s critical to work with family law attorneys, tax advisors, and structured settlement consultants.
Agreements should include contingencies for default, death, or accelerated payout scenarios.
Funds are often placed in escrow, trust, or annuity-backed instruments to ensure reliability of payments.
Explore Related Wealth Planning Resources
Keywords: structured divorce settlement, installment sale strategy, high-net-worth divorce, IRC Section 453, tax deferral in divorce