[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"detail-sidebar-cat-0-en-105":3,"doc-seo-203348-105":59,"doc-detail-203348-en":131},{"code":4,"msg":5,"data":6},0,"success",[7,13,18,23,28,33,38,43,48,51,55],{"id":8,"doc_module":4,"doc_module_name":9,"category_name":10,"show_sort_weight":11,"slug":12},1,"Document","Story & Novel",90,"story-novel",{"id":14,"doc_module":4,"doc_module_name":9,"category_name":15,"show_sort_weight":16,"slug":17},2,"Literature",80,"literature",{"id":19,"doc_module":4,"doc_module_name":9,"category_name":20,"show_sort_weight":21,"slug":22},4,"Exam",70,"exam",{"id":24,"doc_module":4,"doc_module_name":9,"category_name":25,"show_sort_weight":26,"slug":27},5,"Comic",60,"comic",{"id":29,"doc_module":4,"doc_module_name":9,"category_name":30,"show_sort_weight":31,"slug":32},6,"Technology",50,"technology",{"id":34,"doc_module":4,"doc_module_name":9,"category_name":35,"show_sort_weight":36,"slug":37},7,"Healthcare",40,"healthcare",{"id":39,"doc_module":4,"doc_module_name":9,"category_name":40,"show_sort_weight":41,"slug":42},8,"Research & Report",30,"research-report",{"id":44,"doc_module":4,"doc_module_name":9,"category_name":45,"show_sort_weight":46,"slug":47},9,"Religion & Spirituality",20,"religion-spirituality",{"id":46,"doc_module":4,"doc_module_name":9,"category_name":49,"show_sort_weight":46,"slug":50},"World Cup","world-cup",{"id":52,"doc_module":4,"doc_module_name":9,"category_name":53,"show_sort_weight":52,"slug":54},10,"Lifestyle","lifestyle",{"id":56,"doc_module":4,"doc_module_name":9,"category_name":57,"show_sort_weight":24,"slug":58},19,"General","general",{"code":4,"msg":60,"data":61},"ok",{"site_id":62,"language":63,"slug":64,"title":65,"keywords":66,"description":67,"schema_data":68,"social_meta":124,"head_meta":126,"extra_data":128,"updated_unix":130},105,"en","s-1821-tackling-predatory-litigation-funding-act","S. 1821 - Tackling Predatory Litigation Funding Act","","S. 1821 amends the Internal Revenue Code of 1986 to establish a tax on income from litigation financing received by third-party entities. The Act creates a new Internal Revenue Code chapter on “Litigation Financing,” imposing a tax based on qualified litigation proceeds and setting an applicable percentage derived from the highest tax rate plus 3.8 percentage points. It defines key terms such as civil action, covered party, and litigation financing agreement, including special treatment for pass-through entities.",{"@graph":69,"@context":123},[70,84,106],{"@type":71,"itemListElement":72},"BreadcrumbList",[73,77,79,82],{"item":74,"name":75,"@type":76,"position":8},"https://docshare.wps.com","Home","ListItem",{"item":78,"name":9,"@type":76,"position":14},"https://docshare.wps.com/document/",{"item":80,"name":40,"@type":76,"position":81},"https://docshare.wps.com/document/research-report/",3,{"item":83,"name":65,"@type":76,"position":19},"https://docshare.wps.com/document/s-1821-tackling-predatory-litigation-funding-act/203348/",{"url":83,"name":65,"@type":85,"image":86,"author":91,"headline":65,"publisher":94,"fileFormat":97,"inLanguage":63,"description":67,"dateModified":98,"datePublished":99,"encodingFormat":97,"isAccessibleForFree":100,"interactionStatistic":101},"DigitalDocument",{"url":87,"@type":88,"width":89,"height":90},"https://docshare.wps.com/thumbnails/s-1821-tackling-predatory-litigation-funding-act/203348.png","ImageObject",300,407,{"name":92,"@type":93},"Aurora","Person",{"url":74,"name":95,"@type":96},"DocShare","Organization","application/pdf","2026-10-18","2026-09-04",true,{"@type":102,"interactionType":103,"userInteractionCount":105},"InteractionCounter",{"@type":104},"ViewAction",13,{"@type":107,"mainEntity":108},"FAQPage",[109,115,119],{"name":110,"@type":111,"acceptedAnswer":112},"What does S. 1821 seek to do?","Question",{"text":113,"@type":114},"S. 1821 amends the Internal Revenue Code of 1986 to establish a tax on income from litigation that is received by third-party entities providing financing for that litigation.","Answer",{"name":116,"@type":111,"acceptedAnswer":117},"How is the tax amount determined under the proposed chapter?",{"text":118,"@type":114},"For each taxable year, the tax equals the applicable percentage of qualified litigation proceeds received by a covered party, with the applicable percentage set as the highest tax rate for the year plus 3.8 percentage points.",{"name":120,"@type":111,"acceptedAnswer":121},"Which parties are considered a “covered party” under the bill?",{"text":122,"@type":114},"A covered party is a third party that receives funds under a litigation financing agreement and is not an attorney representing a party to the civil action, without regard to whether the third party is organized in the United States or elsewhere.","https://schema.org",{"og:url":83,"og:type":125,"og:title":65,"og:site_name":95,"og:description":67},"article",{"robots":127,"canonical":83},"index,follow",{"doc_id":129,"site_id":62},203348,1788559959,{"code":4,"msg":5,"data":132},{"doc_id":129,"user_id":133,"nickname":92,"user_avatar":134,"doc_module":4,"category_id":39,"category_name":40,"doc_title":65,"doc_description":67,"doc_content":135,"file_id":136,"file_url":137,"file_type":138,"file_size":139,"view_count":105,"is_deleted":4,"is_public":8,"is_downloadable":8,"audit_status":8,"page_count":140,"language":141,"language_code":63,"site_id":62,"html_lang":63,"table_of_contents":142,"faqs":143,"seo_title":144,"seo_description":67,"update_tm":130,"read_time":145,"preview_page_count":4},4810365810221,"https://ap-avatar.wpscdn.com/davatar_155a257f0dc6eb9ab79c44ca47cae57d","II  \n119TH CONGRESS 1ST SESSION  \nS. 1821  \nTo amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation.  \nIN THE SENATE OF THE UNITED STATES  \nMAY 20, 2025  \nMr. TILLIS introduced the following bill; which was read twice and referred to the Committee on Finance  \nA BILL  \nTo amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation.  \n1 Be it enacted by the Senate and House of Representa- 2 tives of the United States of America in Congress assembled, 3 SECTION 1. SHORT TITLE.  \n4 This Act may be cited as the ‘‘Tackling Predatory 5 Litigation Funding Act’’.  \n2  \n1 SEC. 2. LITIGATION FINANCING.  \n2 (a) IN GENERAL.—Subtitle D of the Internal Rev- 3 enue Code of 1986 is amended by adding at the end the  \n4 following new chapter:  \n5 ‘‘CHAPTER 50B—LITIGATION FINANCING  \n‘‘Sec. 5000E–1 . Tax imposed.  \n‘‘Sec. 5000E–2 . Definitions.  \n‘‘Sec. 5000E–3 . Special rules.  \n6 ‘‘SEC. 5000E–1. TAX IMPOSED.  \n7 ‘‘(a) IN GENERAL.—A tax is hereby imposed for each 8 taxable year in an amount equal to the applicable percent- 9 age of any qualified litigation proceeds received by a cov- 10 ered party.  \n11 ‘‘(b) APPLICABLE PERCENTAGE.—For purposes of  \n12 subsection (a), with respect to any taxable year, the appli- 13 cable percentage shall be the amount (expressed as a per- 14 centage) equal to the sum of—  \n15 ‘‘(1) the highest rate of tax imposed by section  \n16 1 for such taxable year, plus  \n17 ‘‘(2) 3.8 percentage points.  \n18 ‘‘(c) APPLICATION OF TAX FOR PASS-THRU ENTI- 19 TIES.—In the case of a covered party that is a partner- 20 ship, S corporation, or other pass-thru entity, the tax im- 21 posed under subsection (a) shall be applied at the entity  \n22 level.  \n23 ‘‘SEC. 5000E–2. DEFINITIONS.  \n24 ‘‘In this chapter—  \n3  \n1 ‘‘(1) CIVIL ACTION.—  \n2 ‘‘(A) IN GENERAL.—The term ‘civil action’  \n3 means any civil action, administrative pro- 4 ceeding, claim, or cause of action.  \n5 ‘‘(B) MULTIPLE ACTIONS.—The term ‘civil  \n6 action’ may, unless otherwise indicated, include  \n7 more than 1 civil action.  \n8 ‘‘(2) COVERED PARTY.—  \n9 ‘‘(A) IN GENERAL.—The term ‘covered  \n10 party’ means, with respect to any civil action,  \n11 any third party (including an individual, cor-  \n12 poration, partnership, or sovereign wealth fund)  \n13 to such action which—  \n14 ‘‘(i) receives funds pursuant to a liti- 15 gation financing agreement, and  \n16 ‘‘(ii) is not an attorney representing a  \n17 party to such civil action.  \n18 ‘‘(B) INCLUSION OF DOMESTIC AND FOR- 19 EIGN ENTITIES.—Subparagraph (A) shall apply  \n20 to any third party without regard to whether  \n21 such party is created or organized in the United  \n22 States or under the law of the United States or  \n23 of any State.  \n24 ‘‘(3) LITIGATION FINANCING AGREEMENT.—  \n4  \n1 ‘‘(A) IN GENERAL.—The term ‘litigation  \n2 financing agreement’ means, with respect to  \n3 any civil action, a written agreement—  \n4 ‘‘(i) whereby a third party agrees to  \n5 provide funds to one of the named parties  \n6 or any law firm affiliated with such civil  \n7 action, and  \n8 ‘‘(ii) which creates a direct or  \n9 collateralized interest in the proceeds of  \n10 such action (by settlement, verdict, judg- 11 ment or otherwise) which—  \n12 ‘‘(I) is based, in whole or part, 13 on a funding-based obligation to—  \n14 ‘‘(aa) such civil action, 15 ‘‘(bb) the appearing counsel, 16 ‘‘(cc) any contractual co- 17 counsel, or  \n18 ‘‘(dd) the law firm of such  \n19 counsel or co-counsel, and  \n20 ‘‘(II) is executed with—  \n21 ‘‘(aa) any attorney rep- 22 resenting a party to such civil ac- 23 tion,  \n24 ‘‘(bb) any co-counsel in the  \n25 litigation with a contingent fee  \n5  \n1 interest in the representation of  \n2 such party,  \n3 ‘‘(cc) any third party that  \n4 has a collateral-based interest in  \n5 the contingency","cbCairHqCXPQy8a8","https://ap.wps.com/l/cbCairHqCXPQy8a8","pdf",257793,11,"English","# Litigation Financing Act Overview\n## Short Title and Purpose\n## Tax Imposed on Qualified Litigation Proceeds\n## Definitions and Scope\n## Special Rules and Pass-Through Entities","[{\"question\":\"What does S. 1821 seek to do?\",\"answer\":\"S. 1821 amends the Internal Revenue Code of 1986 to establish a tax on income from litigation that is received by third-party entities providing financing for that litigation.\"},{\"question\":\"How is the tax amount determined under the proposed chapter?\",\"answer\":\"For each taxable year, the tax equals the applicable percentage of qualified litigation proceeds received by a covered party, with the applicable percentage set as the highest tax rate for the year plus 3.8 percentage points.\"},{\"question\":\"Which parties are considered a “covered party” under the bill?\",\"answer\":\"A covered party is a third party that receives funds under a litigation financing agreement and is not an attorney representing a party to the civil action, without regard to whether the third party is organized in the United States or elsewhere.\"}]","S. 1821 - Tackling Predatory Litigation Funding Act | PDF",28]