Click hear to listen to the radio interview on this subject.
Lance Wallach, National Society of Accountants Speaker of the Year and member of the American Institute of CPAs faculty of teaching professionals, is a frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters. He speaks at more than ten conventions annually and writes for over fifty publications. Lance has written numerous books including Protecting Clients from Fraud, Incompetence and Scams published by John Wiley and Sons, Bisk Education's CPA's Guide to Life Insurance and Federal Estate and Gift Taxation, as well as AICPA best-selling books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots. He does expert witness testimony and has never lost a case. Mr. Wallach may be reached at 516/938.5007, wallachinc@gmail.com, or at www.taxaudit419.com or www.lancewallach.com.
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.
Dolan Media Newswires 01/22/2010
ReplyDeleteSmall business retirement plans fuel litigation
Small businesses facing audits and potentially huge tax penalties over certain types of retirement plans are filing lawsuits against thos
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Tuesday, April 19, 2011
ReplyDeleteLance Wallach tells national radio audience how IRS can collect billions by eliminating its bureaucracy & incompetence & going after the real culprits
Click hear to listen to the radio interview on this subject.
Lance Wallach, National Society of Accountants Speaker of the Year and member of the American Institute of CPAs faculty of teaching professionals, is a frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters. He speaks at more than ten conventions annually and writes for over fifty publications. Lance has written numerous books including Protecting Clients from Fraud, Incompetence and Scams published by John Wiley and Sons, Bisk Education's CPA's Guide to Life Insurance and Federal Estate and Gift Taxation, as well as AICPA best-selling books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots. He does expert witness testimony and has never lost a case. Mr. Wallach may be reached at 516/938.5007, wallachinc@gmail.com, or at www.taxaudit419.com or www.lancewallach.com.
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.
Posted by Lance Wallach at 12:10 PM
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Labels: abusive tax shelters, AM, Audits, CBS 60 minutes, finance, interview, IRS, KMJ, KMJ-580, KMJ580, Lance Wallach, offshore trusts, radio, Ray Appleton, show, talk, tax, tax shelters, taxes
Lance WallachOctober 25, 2013 at 9:38 AM
Dolan Media Newswires 01/22/2010
Small business retirement plans fuel litigation
Small businesses facing audits and potentially huge tax penalties over certain types of retirement plans are filing lawsuits against thos
Lance Wallach can be reached at: LaWallach@aol.com- 516-938-5007- or www.vebaplan.com
Lance Wallach | BenefitsPro
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Section 79, Captive Insurance, IRS Audits and Lawsuits on 419 and ...
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attorneys, CPAs & ex IRS Agents has over 25 years of professional experience! We believe that no firm has more experienced professionals to assist our clients
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Captive Insurance & 419 Plans Litigation
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412i-419 Plans
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Tuesday, March 25, 2014
Captive Insurance & 419 Plans Litigation: September 2013
Captive Insurance & 419 Plans Litigation: September 2013
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Couverture Protecting Clients from Fraud, Incompetence and Scams
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Protect your clients – and yourself – from all kinds of financial chicanery and stupidity with this vital new bookIt 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 bookPinpoints 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 Mana
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Reportable Transactions &419 Plans Litigation
ReplyDelete419e,welfare,benefit,medical,retirement,plan,benefit,design,installation,strategies,pension,specialists,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,
Thursday
Abusive 412(i) Tax Shelter Litigation. Lance Wallach, expert witness.
Parties: Typically, these transactions will include an Insurance company, accountant, tax attorney, and a promoter (someone with an insurance background, perhaps an actuary, who knows how to structure the policy itself). These groups will use insurance brokerages and sub-agents (licensed in the various states) to sell the policies themselves.
Insurance Companies
• American General Life Insurance Company
• Indianapolis Life Insurance Company
• Hartford Life And Annuity Insurance Company
• Pacific Life Insurance Company Met Life
Promoters/Attorneys/Accountants
• Kenneth Hartstein Economic Concepts, Inc.
• Pension Services, Llc
• Bryan Cave Llp (National Law Firm That Provided Generic Tax Opinion Letters)
• Richard Smith (Attorney With Bryan Cave)
How These Plans Work:
In the late 1990’s, the individuals and groups above devised a scheme to sell abusive tax shelters under the auspices of Section 412(i) of the tax code. A 412(i) is a defined benefit pension plan. It provides specific retirement benefits to participants once they reach retirement and must contain assets sufficient to pay those benefits. A 412(i) plan differs from other defined benefit pension plans in that it must be funded exclusively by the purchase of individual life insurance products. To create a 412(i) plan, there must be a trust to hold the assets.
The employer funds the plan by making cash contributions to the trust, and the Code allows the employer to take a tax deduction in the amount of the contributions, i.e. the entire amount. The trust uses the contributed funds to purchase some combination of life insurance products (insurance or annuities) for the plan. As the plan participants retire, the trust will usually sell the policies for their present cash value and purchase annuities with the proceeds.
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Section 79, Captive Insurance, IRS Audits and Lawsuits on 419 and 412i Plans
By Lance Wallach, CLU, CHFC Abusive Tax Shelter, Listed Transaction, Reportable Transaction Expert Witness
PhoneCall Lance Wallach at (516) 938-5007
IRS Attacks Business Owners in 419, 412, Section 79 and Captive Insurance Plans Under Section 6707A - By Lance Wallach - Taxpayers who previously adopted 419, 412i, captive insurance or Section 79 plans are in big trouble. 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."
These plans were sold by insurance agents, financial planners, accountants and attorneys seeking large life insurance commissions. 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
Captive Insurance & 419 Plans Litigation
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MONDAY, DECEMBER 2, 2013
Section 79, Captive Insurance, IRS Audits and Lawsuits on 419 and 412i Plans. Lance Wallach, expert witness.
IRS Attacks Business Owners in 419, 412, Section 79 and Captive Insurance Plans Under Section 6707A - By Lance Wallach - Taxpayers who previously adopted 419, 412i, captive insurance or Section 79 plans are in big trouble. 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."
These plans were sold by insurance agents, financial planners, accountants and attorneys seeking large life insurance commissions. 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.
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Managing Director
Specializing in the following services:
"IRS audit appeals"
U.S. 'Tax Court' cases
Multinational taxation consulting
Recovering losses from insurance companies
& brokerage firms
Tax shelter analysis
Pension plan reviews & evaluations
419 & 412i benefit plan analysis
419 & 412i plan remediation
Offshore tax shelter issues
IRS listed transactions" assistance
Expert witness testimony for:
IRS Taxes
Insurance & retirement plan cases
The Offices of Lance Wallach
516-938-5007 Vebaplan.org
"America's leading tax
representation firm."(TM)
Serving
clients
nationwide
Call us today:
516-938-5007
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The Lance Wallach Network
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Our consulting attorneys, CPAs & ex IRS agents
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Expert Witness in IRS tax and finance cases.
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Expert Witness Lance Wallach is a proven winner in taxation and finance cases, ... listed transactions, material advisor litigation, and matters involving IRS penalties. ... which was issued in response to trust arrangements sold to companies that were ..... Author of AICPA Course on Taxation and Use of Private Annuity Trusts
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Reportable Transactions .com: IRS Audits 419, 412i, Captive Insurance Plans With...
Reportable Transactions .com: IRS Audits 419, 412i, Captive Insurance Plans With...: By Lance Wallach June 2011 The IRS started aud...
As an expert witness Lance Wallach side has never lost a case
MONDAY, APRIL 22, 2013
Sometimes the IRS might disagree with planning you did with other advisors and you need to find help to ensure that your rights are protected, the facts are interpreted accurately and the law applied correctly. Lance Wallach is among the few in this country who fully understand the mechanics and legal issues surrounding what has become known as “419 Plans,” often welfare benefit plans for small companies funded with life insurance. For that reason taxpayers throughout the country seek his services of his ex IRS agents and tax attorney CPAs in dealing with the Internal Revenue Service in audits, appeals and in the Tax Court.
Expert Witness
Frankly, not everybody does it right. Whether through ignorance or ill-intent, some folks sell insurance based programs with tax benefits, such as419 Plans and 412(i) Plans, captive insurance, section 79 scams, or promote premium financing or STOLI programs to unsuspecting consumers leaving the consumer to be eaten alive, either by the IRS or by a turn in the economy, when all goes wrong. But the opposite is also true. One 419 Plan and some 412(i) Plans are very well designed and flawlessly implemented but the IRS just shoots first and aims second. Some legitimate premium financing might miscue. Building off of Lances knowledge of life insurance and the many ways life insurance has been and can be used in tax and wealth planning, lawyers for both plaintiffs and defendants throughout the US seek Lances services as an expert witness in cases between consumers and those who sold them these programs that develop after the IRS, right or wrong, initiates an audit or the investment goes under water. In looking for an expert witness examine the past. As an expert Lance Wallach’s side has never lost a case. Who else can say that?
Posted by Lance Wallach at 12:26 PM
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Labels: 412i, 412i plans, 419, 419 Plans, Captive Insurance Plans, IRS Audits, Lance Wallach, Lance Wallach Expert Witness, Reportable Transactions
2 comments:
Lance WallachApril 4, 2014 at 4:43 AM
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Google Lance Wallach, and google whoever is giving you advice; Who seems more credible?
Remember, many advisory firms offer financial planning, insurance, and investment services,
but the difference is that Lance Wallach wrote the books on life insurance as well as
financial and estate planning that the other consultants learn from!
If you want to sleep soundly at night, don't go to the students for your financial solutions,go to the one who teaches them - Lance Wallach!
National Office
516-938-5007
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To follow Lance on twitter click the link below.
@LanceWallach
Lance Wallach, Managing Director, is the
nation's leading expert on employee benefit plans,
tax problem resolution and IRS audit defense.
Mr. Wallach is a member of the AICPA faculty of
teaching professionals & a renowned national
expert in many court cases. He is the author of
many best selling financial & law books, including:
* "Wealth Preservation Planning" by the
National Society of Accountants
* "The CPA's Guide to Federal & Estate
Gift Taxation" published by Bisk
* The AICPA's "The team approach to Tax,
Financial & Estate planning."
* "The CPA's Guide to Life Insurance" by
Bisk CPEasy
* Avoiding Circular 230 Malpractice Traps
and Common Abusive Small Businesss Hot
spots by the AICPA, author/moderator
Lance Wallach
Trust,Beta 419,Millennium Plan,Bisys,Creative Services Group,Sterling Benefit Plan,Compass 419,Niche 419,CRESP,Sea Nine Veba, American Benefits Trust, National Benefit Plan and Trust, ABT, Professional Benefits Trust Benistar 419 Plan, nova trust, Grist mill trust, Sadi Trust IRS raids, Millennium 419 Plan,Bisys 419,Creative Services Group 419 Plan,Sterling Benefit 419 Plan,CRESP 419,Sea Nine Veba 419, National Benefit Plan and Trust 419, American Benefits Trust 419,ABT 419,Old Mutual, Allmerica Financial, American Heritage Life, Commercial Union Life, National Life of Vermont, Old Line Life, Security Mutual Life, West Coast Life "Grist Mill Trust" "Real Veba""Section 79 GEAR" GEAR" "United Financial Group" "Kenny Hartstein" "Millennium Plan" Kenny Hartstein" "Millennium Plan" "Tom Crosswhite" "Greg Roper""captive insurance" cresp "Ridge Plan" "Professional benefits Trust" "PBT " "Professional Planning Associates" "National Pension Associate" "NPA""Heritage Plan" ""Insurance fraud""pension and benefit plan fraud""insurance company fraud""ECI Pension Services""Pension Professionals of America""ABI""Hartford""AIG""Indy Life""Indianapolis Life""Advantage" Names of People who SOLD: "Kenny Hartstein""Dennis Cunning""Steve Toth""Michael Sonnenberg"Larry Bell""Scott Ridge""Randall Smith""Greg Roper""Tracy Sunderlage""Warren Trust""Joseph Donnelly""Norm Bevan""Judy Carsrud""Dan Carpenter""Ed Waesche" "Tom Crosswhite""David Struckman""George Huff" "Tom Crosswhite" "Greg Roper""Christopher Jarvis" David Mandell" Gen Von Oder Insurance Companies -- need to be 412 AND 419: Hartford 419, Pacific Life 419, PAC Life 419, AVIVA, 419, Indianpolis Life, Penn Mutual419,Bankers Life 419, John Hancock 419, Security Mutual 419, Transamerica 419,Prudential 419, Kansas City Life 419, Mass Mutual419, Guardian 419, Amerus 419, Wells Fargo 419, Fifth Third Bank 419, Arrow Head Trust 419, U.S. Benefits Group, Benefit Plan Advisors, Rex Insurance Service,Advantage,AIG, Old Mutual, Allmerica Financial, American Heritage Life, Commercial Union Life, National Life of Vermont, Old Line Life, Security Mutual Life, West Coast Life
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ReplyDeleteReportable Transactions & 419 Plans Litigation: CJA and associates 419 412i section 79 scam audits...
Reportable Transactions & 419 Plans Litigation: CJA and associates 419 412i section 79 scam audits...: CJA and associates 419 412i section 79 scam audits lawsuits
Posted by Lance Wallach at 6:36 AM