Structured Assignments Inc. was founded in 2010 as an entity for the purpose of accepting non-qualified assignments of periodic payment obligations. It is guided by an esteemed Board of Directors, utilizes the Royal Bank of Canada (the largest bank in the Caribbean) for all banking needs and was established with advice from the renowned law firm Chancery Chambers.
As a Barbados International Business Company (IBC), Structured Assignments, Inc. is subject to the legal and regulatory authorities of Barbados. Additionally, since SAI conducts business with US clients, it has obtained U.S. IRS Tax Identification Number and is compliant with FATCA by obtaining its GIIN. The assignment company is domiciled and managed in Barbados in order to make use of the benefits of the US-Barbados Tax Treaty so that the ownership of the funding assets does not trigger double taxation.
An assignment company organized as a United States corporation would generally be subject to tax on the receipt of a payment for assignment of a periodic payment obligation (fee for services rendered) as well as any interest gain from the assets it purchased and owned. Further, it would not have any offsetting deductions upon the purchase of the funding assets until and as payments were made to the holder of the assets (e.g., as economic performance occurs). While there is an exception for this under Section 130 of the Internal Revenue Code, it is limited to periodic payment obligations that are tax exempt under Section 104(a)(1) or 104(a)(2) of the Code. Barbados is a highly regulated jurisdiction with a well-established and long-standing tax treaty with the United States that allows for the assignment of payment obligations and asset ownership in a tax efficient manner.
TRUST AND EXPERIENCE
WHO WE ARE
Sir Trevor Austin Carmichael was born in Barbados and educated at Harrison College and the University of the West Indies, Mona, Jamaica. After pursuing post graduate studies in the United States, he was called to the United Kingdom Bar as a member of the Middle Temple in London and the Barbados Bar in December of 1977. As a lawyer, he has been engaged in all facets of the law. His original practice areas spanned criminal, constitutional, labor, divorce, trademarks and later he has focused on commercial, charities and environmental law. He is a member of the International Bar Association, the Inter-American Bar Association and a committee member of the Inter-American Bar Foundation as well as an associate member of the Canadian Bar Association. He holds membership in the International Tax Planning Association, the International Fiscal Association and was one of the parties responsible for establishing a Barbados chapter of the International Fiscal Association of which he is Charter President. He has authored over one hundred articles and monographs in the areas of Law, Economics and Public Policy and is the Founder of Chancery Chambers, a Barbados law firm engaged primarily in international business law, environmental law and the law relating to charities.
BOARD OF DIRECTORS
SEAN J. COLEMAN, ESQ.
PRINCIPAL, INTEGRATED FINANCIAL SETTLEMENTS
Mr. Coleman is a Principal, the Chief Operating Officer, and General Counsel of Integrated Financial Settlements, Inc.(“IFS”) IFS wholly-owns four (4) structured settlement consulting firms compromising more than forty percent (40%) of the US national market and originating more than $2 billion in annual structured settlement annuities. Mr. Coleman also is one of the founders and the Manager of Alpha Artists, LLC, one of the leading designers of equity indexed annuities in the United States. Mr. Coleman has over 19 years of experience in the structured settlement industry, having originally started representing Millennium Settlements, Inc. in 1995. Mr. Coleman received his undergraduate degree with honors in 1991 from Princeton University, in Princeton, New Jersey, and his law degree in 1995 from University of Virginia School of Law, in Charlottesville, Virginia. He is a member of the Georgia and Atlanta Bar Associations and is active in the National Structured Settlements Trade Association, currently serving as chairman of its Legislative and Regulatory committee.
SIR TREVOR CARMICHAEL, KA, LVO, QC
Archie Cuke has a long and successful track record in business in Barbados and abroad starting with Price Waterhouse in Canada where he obtained his C.A. and M.B.A. His career has covered almost 30 years in Canada and the last 7 years back in his native Barbados including senior management roles and management consulting in the international business, financial services and investment areas. Archie’s background in the Barbados international business arena and senior management experience enables him to provide Structured Assignments, Inc. with the financial leadership to implement its strategic plan.
ARCHIE CUKE, CA, MBA
Ms. Hunte consults on the day to day operations for Structured Assignments. She brings over a decade of experience managing the administrative affairs of Barbados based assignment companies.
KYLE LORENZO RUDDER, ACCA
Kyle Rudder is a qualified accounting professional and the current Vice President of Centurion Assurance Services Ltd., a management company located in Limegrove Lifestyle Centre, Holetown, St. James, Barbados. Kyle is a former student of Queen’s College and recipient of a Barbados Exhibition. He graduated from the University of the West Indies, Cave Hill Campus with First Class Honors in Economics & Accounting (BSc.). Thereafter, he launched his career by joining the audit department at KPMG (Barbados). This resulted in him acquiring over six years’ experience in financial statement audits in various industries including insurance, banking, investment banking, retail, hotel, government, education and telecommunications. Kyle gained acceptance into the Association of Chartered Certified Accountants (ACCA) in 2012 and is also a member of the Institute of Chartered Accountants of Barbados (ICAB). In a quest to further his career beyond the realm of audit, he acquired a position as Account Executive at UI Management Inc. This afforded him the opportunity to gain further knowledge in captive insurance management and created the platform for his current post.
FEE STRUCTURE PLUS (TM)
Integrated Financial Settlements, the leading provider of structured settlements in the United States, has developed Fee Structure Plus (TM) - an innovative tax management program for attorneys working under contingency fee agreements. This program offers plaintiff attorneys a unique alternative to traditional structured attorney fee options.
Fee Structure Plus (TM) allows attorneys to have their contingency-based attorney fees placed in a program that will enjoy market related returns.
The introduction of Fee Structure Plus (TM) represents the next generation of structured attorney fees. In addition to tax deferral on contingency fees, deferred funds may be allocated to market-related investment portfolios.
Attorneys can select a passive or active investment management approach using a respected trust company or their own financial advisor.
The firm with its’ affiliate, Chancery Corporate Services Limited, offers professional advice and guidance for International and local clients on the use of the appropriate entities such as International Business Companies, Societies with Restricted Liabilities, International Financial Services Companies and Exempt Insurance Companies. It also provides corporate advisory, corporate secretarial and administrative services to local, regional, international and multinational companies.
Chancery Chambers regularly provides tax advice and opinions in international and domestic transactions and in the structuring of investments. It has also been a leader in developing tax advantaged structures working in conjunction with accounting firms and regulatory authorities.
CHANCERY CHAMBERS, ATTORNEYS AT LAW
INTEGRATED FINANCIAL SETTLEMENTS
The IFS family of companies comprises EPS Settlements Group, IFS Special Markets, Mass Tort Settlement Services, Millennium Settlements, Structured Financial Associates, Providio MediSolutions and JMW Settlements with a workforce of over 200 professional structured settlement consultants.
Combined, the IFS organization places approximately $2 billion in annual structured settlement annuities, a 40% market share in the United States. IFS has provided Structured Settlements services to its clients for decades and has unmatched expertise and experience in helping to resolve financial and employment related claims as well as traditional structured settlements for physical injury and Workers’ Compensation claims.
RBC is a diversified financial services company and provides a variety of financial services to personal, business, public sector and institutional clients. Currently RBC employs approximately 78,000 full and part-time employees who serve over 16 million clients in Canada, the United States and 39 other countries including Barbados.
ROYAL BANK OF CANADA (RBC)
The independent audit of Structured Assignments Inc.’s financial statements is performed annually by BDO Barbados.