Over the last few weeks I have been diligently outlining tax planning strategies for trial attorneys with contingent fee income. These strategies have ranged from structured settlement arrangements using private placement variable deferred annuities (PPVA), captive insurance, and Qualified Settlement Funds (QSFs) combined with private placement variable annuities. In my last installment I introduced structured settlement life insurance, a new concept for trial attorneys. Structured settlement life insurance is a powerful tool that combines the benefits of a Qualified Settlement Fund (QSF) and private placement life insurance (PPLI) to provide a powerful combination of deferred compensation along with tax-free income and benefits for the trial attorney and his family. The same benefits are achievable for the claimant such as the UBS Whistleblower. In Part 5, I focused on the utility of the QSF from an investment funding perspective to illustrate how private placement life insurance can be used in a split dollar life insurance funding format in order to create a scenario where the trial attorney is able to create a retirement fund that exploits the tax advantages of life insurance — (I) Tax-free inside buildup of the policy cash value (2) Tax-free lifetime distributions from the policy through policy loans and withdrawals. (3) Income and Estate-tax free death benefit. I thought it would be useful to focus on the case of the UBS Whistleblower (Brad Birlcfeld) situation to illustrate what could have been accomplished in structuring the tax consequences of his record $104 million settlement award from the IRS in conjunction with his role as a whistleblower. Unlike cases that involve physical injury that result in tax-free treatment for the plaintiff, a Whistleblower case results in taxable treatment at ordinary rates for both the Whistleblower and his attorney. Through sophisticated tax planning, the UBS Whistleblower would have demonstrated clearly to