Meet The Author-Lance Wallach For More Information Click Link Below:
Protecting Clients from Fraud, Incompetence and Scams Pub. Date: 2/22/2010Publisher: Wiley, John & Sons, Incorporated
Note:This NOOK Book can be purchased in bulk. Please email us for more information.
More About This Book
LANCE WALLACH, CLU, CHFC, is a leading speaker on accounting and taxation topics and the author of numerous AICPA CPE exam publications. In addition to developing CPE courses, he is also a member of the AICPA faculty of teaching professionals, and has been featured in the Wall Street Journal, the New York Times, Bloomberg Financial News, NBC, National Public Radio's All Things Considered, and other radio talk shows. Mr. Wallach is listed in Who's Who in Finance and Business.
Table of Contents
Acknowledgments.
Introduction: Every Accountant and Attorney Should Read This Book.
CHAPTER 1 Meltdown.
The Party's Over.
We All Know The Result.
Grim Statistics.
Retirement Plans and the IRS.
The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.
Tuesday, March 25, 2014 Raymond Ankner -Expected to be the biggest life insurance failure in Illinois : Report: #1045981 Complaint Review: CJA Marketing Raymond Ankner -Expected to be the biggest life insurance failure in Illinois : Report: #1045981 Complaint Review: CJA Marketing: CJA Marketing CJA and Associates Sold defective retirement plans costing us hundreds of thousands of dollars Beware Of This Company T...
mall Business Tax News Strategic Advice on the Tax Implications of Business Planning March 2004 UPDATE ON IRS CRACKDOWN ON ABUSIVE 412(i) PLANS By Lance Wallach & Ira Kaplan
On Friday, February 3, 2004, the IRS issued proposed regulations concerning the valuation of insurance contracts in the context of qualified retirement plans.
The IRS says that it is no longer reasonable to use the cash surrender value or the interpolated terminal reserve as the accurate value of a life insurance contract for income tax purposes. The IRS issued proposed regulations stating that the value of a life insurance contract in the context of qualified retirement plans should be the contract’s fair market value.
The Service acknowledged in the regulations (and in a revenue procedure issued simultaneously) that the fair market value standard could create some confusion among taxpayers. They addressed this possibility by describing a safe harbor position.
When I addressed the American Society of Pension Actuaries Annual National Convention, the IRS chief actuary also spoke about attacking abusive 412(i) pensions.
A “Section 412(i) plan” is a tax-qualified retirement plan that is funded entirely by a life insurance contract or an annuity. The employer claims tax deductions for contributions that are used by the plan to pay premiums on an insurance contract covering an employee. The plan may hold the contract until the employee dies, or it may distribute or sell the contract to the employee at a specific point, such as when the employee retires.
“The guidance targets specific abuses occurring with Section 412(i) plans”, stated Assistant Secretary for Tax Policy Pam Olson. “There are many legitimate Section 412(i) plans, but some push the envelope, claiming tax results for employees and employers that do not reflect the underlying economics of the arrangements.” Or, to put it another way, tax deductions are being claimed, in some cases, that the Service does not feel are reasonable given the taxpayer’s facts and circumstances.
“Again and again, we’ve uncovered abusive tax avoidance transactions that game the system to the detriment of those who play by the rules,” said IRS Commissioner Mark W. Everson.
I have been published by the AICPA and others for years about these and similar abuses. Finally, the IRS is doing something. If someone is in an abusive 412(i) plan, they had better seek counsel quickly.
Editor's note: The author and publisher are not rendering professional advice and assume no liability in connection with its use. Consult your tax adviser and accountant before making any investment or tax-related decisions.•
Lance Wallach is a member of Small Business Tax News’ Advisory Board. He is a frequent speaker on tax-related subjects including VEBAs, pensions, and tax-oriented strategies.• Ira Kaplan, Esq., CPA, MBA, is a national speaker and author. For more information call Lance Wallach at (516)938-5007.
Section 79 Plans 412i, 419e plans litigation and IRS Audit Experts for abusive insurance reportable or listed transactions by the IRS,Section 79, Section 79 Lawsuits,412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.Benistar,412i Lawsuits,419 lawsuits,412i Help,419 Help, IRS Audits,412i Problems,412i problems, Expert Witness Lance Wallach,412i Help,419 Help, Benistar Lawsuits, 412i lawsuits,419 lawsuits,
Wednesday, January 8, 2014
WHAT IS A SECTION 79 PLAN? Section 79 plans are commonly known for the $50,000 free term life insurance they can provide for employees. Less commonly known is that Section 79 plans can also provide permanent life insurance. These plans are employee benefit plans established under Section 79 of the Internal Revenue Code. Section 79 plans are non-qualified plans but they are tax-deductible plans for the adopting employer. WHAT ARE THE BENEFITS OF A SECTION 79 PLAN? Section 79 plans provide life insurance benefits for employees paid for by the employer. The life premiums paid are 100% tax-deductible to the business. The "economic benefit" of the life insurance is reportable as taxable income for the insured employee. Only life insurance in excess of $50,000 is reportable. The "economic benefit" is determined using the rates under Table I ( Reg. §1.79-3(d)(2)). When permanent insurance is used the reportable economic benefit can be as little as 60% of the actual premium paid and deducted. This can provide a tax-advantaged way to purchase personal life insurance. CAN ANY BUSINESS ADOPT A SECTION 79 PLAN? Section 79 plans are only for employees. Self-employed individuals, partners and owners of S corporations are not employees. For an owner to participate the sponsoring employer must be a C Corporation.
Protecting Clients from Fraud, Incompetence and Scams Lance Wallach View More by This Author This book is available for download with iBooks on your Mac or iOS device, and with iTunes on your computer. Books can be read with iBooks on your Mac or iOS device. Description Protect your clients – and yourself – from all kinds of financial chicanery and stupidity with this vital new book
It doesn't matter if a financial error was made because of malice or ignorance – the end result is that you lose money. Luckily, you don't have to sit idly and take it. If you have Protecting Clients from Fraud, Incompetence and Scams, you can identify and avoid the dysfunctional sectors of the financial industry, steer clear of the fallout from the Madoff Era, and guide your clients to real, healthy, sustainable returns. This powerful book
Pinpoints dysfunctional sectors within the financial industry and offers advice against frauds and scammers Shows how a team approach to asset management can ward off financial predators Offers practical strategies and tools to combat client risk for Risk and Asset Management Offering insightful information to protect your clients from all sorts of frauds and incompetence, this essential guide equips you with tips and techniques to spot the red flags of fraud and prevent it before it starts.
Captive Insurance & 419 Plans Litigation 412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions,412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions,Captive Insurance,Captive Insurance Lawsuits,412i Lawsuits,419 lawsuits,412i Help,419 Help, IRS Audits,412i Problems,412i problems, Expert Witness Lance Wallach,412i Help,419 Help, Benistar Lawsuits, 412i lawsuits,419 lawsuits,
MONDAY, SEPTEMBER 16, 2013 Internal Revenue Code Section 79 Plans and Captive Insurance History Internal Revenue Code Section 79 Plans and Captive Insurance History Posted by Lance Wallach at 9:47 AM 3 comments: Labels: Captive Insurance, IRC, irs, Lance Wallach, lance wallach expert witness, section 79, Section 79 Plans Newer Posts Older Posts Home Subscribe to: Posts (Atom) LANCE WALLACH IS A NATIONALLY RECOGNIZED EXPERT, AUTHOR, AICPA INSTRUCTOR AND SPEAKER. "Protecting Clients from Fraud, Incompetence, and Scams" published by John Wiley & Sons Mr. Wallach is the National Society of Accountant's Speaker of the Year and the author of numerous professional books, including: "Avoiding Circular 230 Malpractice Traps and Common Abusive Small Businesss Hot Spots" by the AICPA - author/moderator Lance Wallach The AICPA's "The team approach to Tax, Financial and Estate Planning." "The CPA's Guide to Life Insurance" by Bisk CPEasy "Wealth Preservation Planning" by the National Society of Accountants "The CPA's Guide to Federal and Estate Gift Taxation" published by Bisk GET OUR FREE $200K REPORT
IRS to Audit Sea Nine VEBA Participating - Veba Health Care vebahealthcarelancewallach.blogspot.com/.../irs-to-audit-sea-nine-veba.h... Dec 1, 2013 - In recent months, I have received phone calls from participants in the Sea Nine VEBA and have learned that the IRS may be auditing many ... You, Lance Wallach and Lance Wallach +1'd this Help with Common IRS Problems: As an expert witness ... irstaxprobs.blogspot.com/2014/.../as-expert-witness-lance-wallach-side.ht... Mar 11, 2014 - KENNETH ELLIOT: Sea Nine VEBA Important ... 419" “Niche 419” CRESP "Sea Nine Veba" “419 plan” 412i 419e "expert witness insurance ... You, Lance Wallach and Lance Wallach +1'd this KENNETH ELLIOT: Sea Nine VEBA Important kennethelliotkaeinsuranceco.blogspot.com/.../sea-nine-veba-important.ht... Jan 7, 2014 - As of August 23,2013, the IRS has closed audits of 12 Sea Nine VEBA plan-participating taxpayers who were referred to Sea Nine by Sarva.
If your CPA, financial advisor, or insurance agent introduced you to one of these plans and now the IRS is after you, contact us immediately. You may be a victim of insurance fraud. We want to help protect your business and your hard-earned income.
Likewise, if you currently participate in one of these plans, and are worried about whether the IRS will penalize you, give us a call. We can help you make sure your plan is legit, and that no one tried to trick you in order to get a huge commission.
How your CPA, financial advisor, or insurance agent may be responsible for your audit:
Improper filing of form 8886 Misrepresentation of the tax code Misunderstanding of the tax code Failure to explain certain details of the plan Bad math/calculations Dishonesty Despite these mistakes or misleadings by your CPA, financial advisor, or insurance agent, the IRS will come after you, the small business owner, if something is amiss. Where is the justice? These advisors should be held responsible for the damages you are incurring. We want to help you fight the people who took advantage of you and make them accountable for their actions.
AXPAYERS WHO PREVIOUSLY ADOPTED 419, 412I, CAPTIVE INSURANCE OR SECTION 79 PLANS ARE IN BIG TROUBLE
June 15, 2011 By Lance Wallach, CLU, CHFC
PhoneCall (516) 938-5007 Expert Witness: Lance Wallach, CLU, CHFC In recent years, the IRS has identified many of these arrangements as abusive devices to funnel tax deductible dollars to shareholders and classified these arrangements as listed transactions." Insurance agents, financial planners, accountants and attorneys seeking large life insurance commissions sold these plans.
In general, taxpayers who engage in a “listed transaction” must report such transaction to the IRS on Form 8886 every year that they “participate” in the transaction, and you do not necessarily have to make a contribution or claim a tax deduction to participate. Section 6707A of the Code imposes severe penalties for failure to file Form 8886 with respect to a listed transaction. But you are also in trouble if you file incorrectly. I have received numerous phone calls from business owners who filed and still got fined. Not only do you have to file Form 8886, but it also has to be prepared correctly. I only know of two people in the U.S. who have filed these forms properly for clients. They tell me that was after hundreds of hours of research and over 50 phones calls to various IRS personnel. The filing instructions for Form 8886 presume a timely filling. Most people file late and follow the directions for currently preparing the forms. Then the IRS fines the business owner. The tax court does not have jurisdiction to abate or lower such penalties imposed by the IRS. To Read More: http://www.hg.org/article.asp?preview=1 Posted by Lance Wallach at 12/7/2012 1:33 PM Categories: uncategorized Tags: 412i IRStaxpenalties IRS taxshelters 419e 412i 6707A benefitplans IRStaxpenalties IRS_tax_penalties benefit_plans tax_shelters
Wednesday, May 28, 2014 More Problems for 419 Plans For years, life insurance companies and agents have tried to find ways of making life insurance premiums paid by business owners tax deductible. This would allow them to sell policies at a "discount." The problem became acute a few years ago with outlandish claims about how §§419A(f)(5) and (6) of the Internal Revenue Code (IRC) exempted employers from any tax deduction limitations. Other inaccurate assertions were made as well, until the Internal Revenue Service (IRS) finally put a stop to such egregious misrepresentations in 2002 by issuing regulations and naming such plans as "potentially abusive tax shelters" (or "listed transactions") that needed to be registered and disclosed to the IRS.
This appeared to put an end to the scourge of scurrilous promoters, as many such plans disappeared from the landscape.
And what happened to the providers that were peddling §§419A(f)(5) and (6) life insurance plans a few years ago? We recently found the answer: Most of them found a new life as promoters of so-called "419(e)" welfare benefit plans.
Meet The Author-Lance Wallach
ReplyDeleteFor More Information Click Link Below:
Protecting Clients from Fraud, Incompetence and Scams Pub. Date: 2/22/2010Publisher: Wiley, John & Sons, Incorporated
Note:This NOOK Book can be purchased in bulk. Please email us for more information.
More About This Book
LANCE WALLACH, CLU, CHFC, is a leading speaker on accounting and taxation topics and the author of numerous AICPA CPE exam publications. In addition to developing CPE courses, he is also a member of the AICPA faculty of teaching professionals, and has been featured in the Wall Street Journal, the New York Times, Bloomberg Financial News, NBC, National Public Radio's All Things Considered, and other radio talk shows. Mr. Wallach is listed in Who's Who in Finance and Business.
Table of Contents
Acknowledgments.
Introduction: Every Accountant and Attorney Should Read This Book.
CHAPTER 1 Meltdown.
The Party's Over.
We All Know The Result.
Grim Statistics.
Retirement Plans and the IRS.
The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.
412i-419 Plans
ReplyDelete419 & 412i benefit plan,abusive tax shelters, Lance Wallach Expert Witness
Tuesday, March 25, 2014
Raymond Ankner -Expected to be the biggest life insurance failure in Illinois : Report: #1045981 Complaint Review: CJA Marketing
Raymond Ankner -Expected to be the biggest life insurance failure in Illinois : Report: #1045981 Complaint Review: CJA Marketing: CJA Marketing CJA and Associates Sold defective retirement plans costing us hundreds of thousands of dollars Beware Of This Company T...
mall Business Tax News
ReplyDeleteStrategic Advice on the Tax Implications of Business Planning
March 2004
UPDATE ON IRS CRACKDOWN ON ABUSIVE 412(i) PLANS
By Lance Wallach & Ira Kaplan
On Friday, February 3, 2004, the IRS issued proposed regulations concerning the valuation of insurance contracts in the context of qualified retirement plans.
The IRS says that it is no longer reasonable to use the cash surrender value or the interpolated terminal reserve as the accurate value of a life insurance contract for income tax purposes. The IRS issued proposed regulations stating that the value of a life insurance contract in the context of qualified retirement plans should be the contract’s fair market value.
The Service acknowledged in the regulations (and in a revenue procedure issued simultaneously) that the fair market value standard could create some confusion among taxpayers. They addressed this possibility by describing a safe harbor position.
When I addressed the American Society of Pension Actuaries Annual National Convention, the IRS chief actuary also spoke about attacking abusive 412(i) pensions.
A “Section 412(i) plan” is a tax-qualified retirement plan that is funded entirely by a life insurance contract or an annuity. The employer claims tax deductions for contributions that are used by the plan to pay premiums on an insurance contract covering an employee. The plan may hold the contract until the employee dies, or it may distribute or sell the contract to the employee at a specific point, such as when the employee retires.
“The guidance targets specific abuses occurring with Section 412(i) plans”, stated Assistant Secretary for Tax Policy Pam Olson. “There are many legitimate Section 412(i) plans, but some push the envelope, claiming tax results for employees and employers that do not reflect the underlying economics of the arrangements.” Or, to put it another way, tax deductions are being claimed, in some cases, that the Service does not feel are reasonable given the taxpayer’s facts and circumstances.
“Again and again, we’ve uncovered abusive tax avoidance transactions that game the system to the detriment of those who play by the rules,” said IRS Commissioner Mark W. Everson.
I have been published by the AICPA and others for years about these and similar abuses. Finally, the IRS is doing something. If someone is in an abusive 412(i) plan, they had better seek counsel quickly.
Editor's note: The author and publisher are not rendering professional advice and assume no liability in connection with its use. Consult your tax adviser and accountant before making any investment or tax-related decisions.•
Lance Wallach is a member of Small Business Tax News’ Advisory Board. He is a frequent speaker on tax-related subjects including VEBAs, pensions, and tax-oriented strategies.•
Ira Kaplan, Esq., CPA, MBA, is a national speaker and author. For more information call Lance Wallach at (516)938-5007.
Section 79 Plans
ReplyDelete412i, 419e plans litigation and IRS Audit Experts for abusive insurance reportable or listed transactions by the IRS,Section 79, Section 79 Lawsuits,412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.Benistar,412i Lawsuits,419 lawsuits,412i Help,419 Help, IRS Audits,412i Problems,412i problems, Expert Witness Lance Wallach,412i Help,419 Help, Benistar Lawsuits, 412i lawsuits,419 lawsuits,
Wednesday, January 8, 2014
WHAT IS A SECTION 79 PLAN?
Section 79 plans are commonly known for the $50,000 free term life insurance they can provide for employees. Less commonly known is that Section 79 plans can also provide permanent life insurance. These plans are employee benefit plans established under Section 79 of the Internal Revenue Code. Section 79 plans are non-qualified plans but they are tax-deductible plans for the adopting employer.
WHAT ARE THE BENEFITS OF A SECTION 79 PLAN?
Section 79 plans provide life insurance benefits for employees paid for by the employer. The life premiums paid are 100% tax-deductible to the business. The "economic benefit" of the life insurance is reportable as taxable income for the insured employee. Only life insurance in excess of $50,000 is reportable. The "economic benefit" is determined using the rates under Table I ( Reg. §1.79-3(d)(2)). When permanent insurance is used the reportable economic benefit can be as little as 60% of the actual premium paid and deducted. This can provide a tax-advantaged way to purchase personal life insurance.
CAN ANY BUSINESS ADOPT A SECTION 79 PLAN?
Section 79 plans are only for employees. Self-employed individuals, partners and owners of S corporations are not employees. For an owner to participate the sponsoring employer must be a C Corporation.
Protecting Clients from Fraud, Incompetence and Scams
ReplyDeleteLance Wallach
View More by This Author
This book is available for download with iBooks on your Mac or iOS device, and with iTunes on your computer. Books can be read with iBooks on your Mac or iOS device.
Description
Protect your clients – and yourself – from all kinds of financial chicanery and stupidity with this vital new book
It doesn't matter if a financial error was made because of malice or ignorance – the end result is that you lose money. Luckily, you don't have to sit idly and take it. If you have Protecting Clients from Fraud, Incompetence and Scams, you can identify and avoid the dysfunctional sectors of the financial industry, steer clear of the fallout from the Madoff Era, and guide your clients to real, healthy, sustainable returns. This powerful book
Pinpoints dysfunctional sectors within the financial industry and offers advice against frauds and scammers
Shows how a team approach to asset management can ward off financial predators
Offers practical strategies and tools to combat client risk for Risk and Asset Management
Offering insightful information to protect your clients from all sorts of frauds and incompetence, this essential guide equips you with tips and techniques to spot the red flags of fraud and prevent it before it starts.
Captive Insurance & 419 Plans Litigation
ReplyDelete412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions,412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions,Captive Insurance,Captive Insurance Lawsuits,412i Lawsuits,419 lawsuits,412i Help,419 Help, IRS Audits,412i Problems,412i problems, Expert Witness Lance Wallach,412i Help,419 Help, Benistar Lawsuits, 412i lawsuits,419 lawsuits,
MONDAY, SEPTEMBER 16, 2013
Internal Revenue Code Section 79 Plans and Captive Insurance History
Internal Revenue Code Section 79 Plans and Captive Insurance History
Posted by Lance Wallach at 9:47 AM 3 comments:
Labels: Captive Insurance, IRC, irs, Lance Wallach, lance wallach expert witness, section 79, Section 79 Plans
Newer Posts Older Posts Home
Subscribe to: Posts (Atom)
LANCE WALLACH IS A NATIONALLY RECOGNIZED EXPERT, AUTHOR, AICPA INSTRUCTOR AND SPEAKER.
"Protecting Clients from Fraud, Incompetence, and Scams" published by John Wiley & Sons
Mr. Wallach is the National Society of Accountant's Speaker of the Year and the author of numerous professional books, including:
"Avoiding Circular 230 Malpractice Traps and Common Abusive Small Businesss Hot Spots" by the AICPA - author/moderator Lance Wallach
The AICPA's "The team approach to Tax, Financial and Estate Planning."
"The CPA's Guide to Life Insurance" by Bisk CPEasy
"Wealth Preservation Planning" by the National Society of Accountants
"The CPA's Guide to Federal and Estate Gift Taxation" published by Bisk
GET OUR FREE $200K REPORT
IRS to Audit Sea Nine VEBA Participating - Veba Health Care
ReplyDeletevebahealthcarelancewallach.blogspot.com/.../irs-to-audit-sea-nine-veba.h...
Dec 1, 2013 - In recent months, I have received phone calls from participants in the Sea Nine VEBA and have learned that the IRS may be auditing many ...
You, Lance Wallach and Lance Wallach +1'd this
Help with Common IRS Problems: As an expert witness ...
irstaxprobs.blogspot.com/2014/.../as-expert-witness-lance-wallach-side.ht...
Mar 11, 2014 - KENNETH ELLIOT: Sea Nine VEBA Important ... 419" “Niche 419” CRESP "Sea Nine Veba" “419 plan” 412i 419e "expert witness insurance ...
You, Lance Wallach and Lance Wallach +1'd this
KENNETH ELLIOT: Sea Nine VEBA Important
kennethelliotkaeinsuranceco.blogspot.com/.../sea-nine-veba-important.ht...
Jan 7, 2014 - As of August 23,2013, the IRS has closed audits of 12 Sea Nine VEBA plan-participating taxpayers who were referred to Sea Nine by Sarva.
If your CPA, financial advisor, or insurance agent introduced you to one of these plans and now the IRS is after you, contact us immediately. You may be a victim of insurance fraud. We want to help protect your business and your hard-earned income.
ReplyDeleteLikewise, if you currently participate in one of these plans, and are worried about whether the IRS will penalize you, give us a call. We can help you make sure your plan is legit, and that no one tried to trick you in order to get a huge commission.
How your CPA, financial advisor, or insurance agent may be responsible for your audit:
Improper filing of form 8886
Misrepresentation of the tax code
Misunderstanding of the tax code
Failure to explain certain details of the plan
Bad math/calculations
Dishonesty
Despite these mistakes or misleadings by your CPA, financial advisor, or insurance agent, the IRS will come after you, the small business owner, if something is amiss. Where is the justice? These advisors should be held responsible for the damages you are incurring. We want to help you fight the people who took advantage of you and make them accountable for their actions.
AXPAYERS WHO PREVIOUSLY ADOPTED 419, 412I, CAPTIVE INSURANCE OR SECTION 79 PLANS ARE IN BIG TROUBLE
ReplyDeleteJune 15, 2011 By Lance Wallach, CLU, CHFC
PhoneCall (516) 938-5007
Expert Witness: Lance Wallach, CLU, CHFC
In recent years, the IRS has identified many of these arrangements as abusive devices to funnel tax deductible dollars to shareholders and classified these arrangements as listed transactions." Insurance agents, financial planners, accountants and attorneys seeking large life insurance commissions sold these plans.
In general, taxpayers who engage in a “listed transaction” must report such transaction to the IRS on Form 8886 every year that they “participate” in the transaction, and you do not necessarily have to make a contribution or claim a tax deduction to participate. Section 6707A of the Code imposes severe penalties for failure to file Form 8886 with respect to a listed transaction. But you are also in trouble if you file incorrectly. I have received numerous phone calls from business owners who filed and still got fined. Not only do you have to file Form 8886, but it also has to be prepared correctly. I only know of two people in the U.S. who have filed these forms properly for clients. They tell me that was after hundreds of hours of research and over 50 phones calls to various IRS personnel. The filing instructions for Form 8886 presume a timely filling. Most people file late and follow the directions for currently preparing the forms. Then the IRS fines the business owner. The tax court does not have jurisdiction to abate or lower such penalties imposed by the IRS.
To Read More:
http://www.hg.org/article.asp?preview=1
Posted by Lance Wallach at 12/7/2012 1:33 PM
Categories: uncategorized
Tags: 412i IRStaxpenalties IRS taxshelters 419e 412i 6707A benefitplans IRStaxpenalties IRS_tax_penalties benefit_plans tax_shelters
Wednesday, May 28, 2014
ReplyDeleteMore Problems for 419 Plans
For years, life insurance companies and agents have tried to find ways of making life insurance premiums paid by business owners tax deductible. This would allow them to sell policies at a "discount."
The problem became acute a few years ago with outlandish claims about how §§419A(f)(5) and (6) of the Internal Revenue Code (IRC) exempted employers from any tax deduction limitations. Other inaccurate assertions were made as well, until the Internal Revenue Service (IRS) finally put a stop to such egregious misrepresentations in 2002 by issuing regulations and naming such plans as "potentially abusive tax shelters" (or "listed transactions") that needed to be registered and disclosed to the IRS.
This appeared to put an end to the scourge of scurrilous promoters, as many such plans disappeared from the landscape.
And what happened to the providers that were peddling §§419A(f)(5) and (6) life insurance plans a few years ago? We recently found the answer: Most of them found a new life as promoters of so-called "419(e)" welfare benefit plans.