412i-419 Planslan contributions far exceed the cost of coverage for the year, and Sunderlage has told Business Protection Plan participants that their premium payments are deductible business expenses. 117. Sunderlage has offered Employee Benefit Scheme participants the option of using their contributions to the Employee Benefit Scheme to make Business Protection Plan premium payments (at least a portion of which would revert to the participant’s offshore trust at the end of each year). 118. Sunderlage has promoted the Business Protection Plan, offshore “asset protection” trust products, and the Employee Benefit Scheme to potential participants at the same offshore conferences. Two companies, Foster & Dunhill Ltd. and BPS International LLC, hosted these conferences until at least 2003. Defendant SRG International Ltd. and BPS International LLC hosted these conferences together until at least 2005. Sunderlage directly or indirectly owned a share of BPS International LLC until in or around 2004, and spoke at these conferences. 119. Until approximately 2006, Fidelity Insurance Company Ltd. (“FICL”) acted as an insurance company issuing the life insurance policies used in the Business Protection Plan and offshore “asset protection” trust products that Sunderlage promoted. FICL is part of the same group of companies as First Fidelity Trust Ltd., which served as co-trustee of the PBT Multiple Employer Plan between 2000 and 2006. 120. In connection with the Business Protection Plan and offshore “asset protection” trust products, Sunderlage (through BPS International LLC, Sunderlage Resource Group, and/or Case: 1:11-cv-04713 Document #: 1 Filed: 07/13/11 Page 30 of 43 PageID #:30 31 defendant SRG International Ltd.) received fees and commissions from the sale of FICL insurance products and the formation of participants’ offshore trusts. 121. Beginning in 2004, some Business Protection Plan and/or offshore “asset protection” trust participants have caused their trusts to utilize policies issued by Acadia Life Ltd. – the same company whose policies are used in the current Maven Structure – rather than FICL policies. FALSE STATEMENTS 122. Sunderlage (personally and through his companies) and SRG International have made or furnished or caused other persons to make or furnish false and/or fraudulent statements with respect to the tax benefits of the Employee Benefit Scheme, including statements that the Owner’s company
412i-419 Planslan contributions far exceed the cost of coverage for the year, and Sunderlage has
ReplyDeletetold Business Protection Plan participants that their premium payments are deductible business
expenses.
117. Sunderlage has offered Employee Benefit Scheme participants the option of using their
contributions to the Employee Benefit Scheme to make Business Protection Plan premium
payments (at least a portion of which would revert to the participant’s offshore trust at the end of
each year).
118. Sunderlage has promoted the Business Protection Plan, offshore “asset protection” trust
products, and the Employee Benefit Scheme to potential participants at the same offshore
conferences. Two companies, Foster & Dunhill Ltd. and BPS International LLC, hosted these
conferences until at least 2003. Defendant SRG International Ltd. and BPS International LLC
hosted these conferences together until at least 2005. Sunderlage directly or indirectly owned a
share of BPS International LLC until in or around 2004, and spoke at these conferences.
119. Until approximately 2006, Fidelity Insurance Company Ltd. (“FICL”) acted as an
insurance company issuing the life insurance policies used in the Business Protection Plan and
offshore “asset protection” trust products that Sunderlage promoted. FICL is part of the same
group of companies as First Fidelity Trust Ltd., which served as co-trustee of the PBT Multiple
Employer Plan between 2000 and 2006.
120. In connection with the Business Protection Plan and offshore “asset protection” trust
products, Sunderlage (through BPS International LLC, Sunderlage Resource Group, and/or
Case: 1:11-cv-04713 Document #: 1 Filed: 07/13/11 Page 30 of 43 PageID #:30
31
defendant SRG International Ltd.) received fees and commissions from the sale of FICL
insurance products and the formation of participants’ offshore trusts.
121. Beginning in 2004, some Business Protection Plan and/or offshore “asset protection”
trust participants have caused their trusts to utilize policies issued by Acadia Life Ltd. – the same
company whose policies are used in the current Maven Structure – rather than FICL policies.
FALSE STATEMENTS
122. Sunderlage (personally and through his companies) and SRG International have made or
furnished or caused other persons to make or furnish false and/or fraudulent statements with
respect to the tax benefits of the Employee Benefit Scheme, including statements that the
Owner’s company