Boris,
thank you for well meant advice in re taxes on future ESCROW payments.
I agree with your CPA, but .....
You know I'm Austrian citizen, am CPA for myself for ages; so I have not to deal with US taxation rules too intense, except for the fiscal effects arising out from the treaty US - Austria, and one thing for sure, I documented already years ago my foreign status and claimed any applicable treaty benefits for chapter 3 purposes to the IRS.
Means I'll have to deal with the Austrian tax authority and between you, me and the bedpost, I'm lucky to say that for certain fiscal circumstances I feel right now similar as a legal AAPL !!!
Good luck to you and all other "ESCROWERs" !!!