• GAAP - FAS 125, paragraph 16 • SAP- NAIC P/P Manual, Chpt. 10 • Tax - IRC 461(h) and 832 (c) - immediate deduction; see also Maxus Energy and Aero Chemical • Tax - IRC 451 - no constructive receipt for an unsecured promise to pay • Tax - IRC 212 - deduction for attorney fees disallowed under AMT rules Go back to Uses What is a non-qualified assignment? Available Markets: Traditional Non-Qualified Available Markets: Structured Sales The Benefits The Process Why are we safe? Taxation and Accounting Issues

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