412i and 419e plans litigation. IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.
Looking for the IRS Number? Call (800)829-1040.
While captive insurance plans are legitimate for large corporations, they are usually not legitimate for small business owners as a way to obtain a tax deduction. I have not yet seen a legitimate Section 79 plan. Recently, I have sent some of the plan promoters’ materials over to my IRS contacts who were very interested in receiving them. Some of my associates are already trying to help defend some unsu google lance or www.taxaudit419.com
Abusive Insurance and Retirement Plans Single-employer section 419 welfare benefit plans are the latest incarnation in insurance deductions the IRS deems abusive. by Lance Wallach Parts of this article are from the AICPA CPE self-study course Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots, by Sid Kess, authored by Lance Wallach.
Many of the listed transactions that can get your clients into trouble with the IRS are exotic shelters that relatively few practitioners ever encounter. When was the last time you saw someone file a return as a Guamanian trust (Notice 2000-61)? On the other hand, a few listed transactions concern relatively common employee benefit plans the IRS has deemed tax-avoidance schemes or otherwise abusive. Perhaps some of the most likely to crop up, especially in small business returns, are arrangements purporting to allow deductibility of premiums paid for life insurance under a welfare benefit plan.
Abusive Insurance and Retirement Plans Single-employer section 419 welfare benefit plans are the latest incarnation in insurance deductions the IRS deems abusive. by Lance Wallach Parts of this article are from the AICPA CPE self-study course Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots, by Sid Kess, authored by Lance Wallach.
Many of the listed transactions that can get your clients into trouble with the IRS are exotic shelters that relatively few practitioners ever encounter. When was the last time you saw someone file a return as a Guamanian trust (Notice 2000-61)? On the other hand, a few listed transactions concern relatively common employee benefit plans the IRS has deemed tax-avoidance schemes or otherwise abusive. Perhaps some of the most likely to crop up, especially in small business returns, are arrangements purporting to allow deductibility of premiums paid for life insurance under a welfare benefit plan.
Abusive Insurance and Retirement Plans Single-employer section 419 welfare benefit plans are the latest incarnation in insurance deductions the IRS deems abusive. by Lance Wallach Parts of this article are from the AICPA CPE self-study course Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots, by Sid Kess, authored by Lance Wallach.
Many of the listed transactions that can get your clients into trouble with the IRS are exotic shelters that relatively few practitioners ever encounter. When was the last time you saw someone file a return as a Guamanian trust (Notice 2000-61)? On the other hand, a few listed transactions concern relatively common employee benefit plans the IRS has deemed tax-avoidance schemes or otherwise abusive. Perhaps some of the most likely to crop up, especially in small business returns, are arrange
Abusive Insurance and Retirement Plans Single-employer section 419 welfare benefit plans are the latest incarnation in insurance deductions the IRS deems abusive. by Lance Wallach Parts of this article are from the AICPA CPE self-study course Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots, by Sid Kess, authored by Lance Wallach.
Many of the listed transactions that can get your clients into trouble with the IRS are exotic shelters that relatively few practitioners ever encounter. When was the last time you saw someone file a return as a Guamanian trust (Notice 2000-61)? On the other hand, a few listed transactions concern relatively common employee benefit plans the IRS has deemed tax-avoidance schemes or
Lance Wallach | LinkedIn www.linkedin.com/in/lancewallach Greater New York City Area - director at taxaudit419.com View Lance Wallach's professional profile on LinkedIn. ... Lance Wallach Consulting and Expert Witness - 419e, 412i, 6707A, IRS 8886 forms, Section 79,. You shared this on Google+ IRS Secrets You Should Know by Lance Wallach - YouTube ► 0:54► 0:54 www.youtube.com/watch?v... YouTube May 18, 2012 - Uploaded by Lance Wallach Get IRS Secrets You Should Know here: http://www.tinyurl.com/LWIRSBook My name is Lance Wallach and I ... More by Lance Wallach - in 57 Google+ circles IRS Audits Focus on Captive Insurance Plans - Lance Wallach www.lancewallach.com/employeeretirementplan.html Benistar, SADI Trust,Beta 419,Millennium Plan,Bisys, Creative Services Group,Sterling Benefit Plan, Compass 419,Niche 419,CRESP,Sea Nine Veba, American ... You shared this on Google+
Material Advisors & 419 Plans Litigation 412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.
Friday, November 1, 2013 Class Action Challenges Propriety of 412(e)(3) Annuities. Lance Wallach, expert witness. On August 1, 2012, a putative class action lawsuit was filed in the District of Connecticut challenging the propriety of certain insurance contracts used to fund defined benefit plans described in section 412(e)(3) of the Internal Revenue Code. U.S. Telemanagement, Inc. v. Fidelity Security Life Insurance Co. et al., No. 3:12-cv-1110 JBA (D. Conn.).
Because we perceive that the complaint is attacking the appropriateness of the product, as well as the specifics of the product that the named defendant sold, it is a lawsuit that potentially could have industry-wide implications. In addition, as plaintiffs in some of the ERISA revenue-sharing lawsuits have attempted to do, the complaint alleges that the insurance company that sold the annuities acted as an ERISA fiduciary of the plans. This lawsuit thus extends the attack on insurance companies, as seen in the revenue-sharing class actions, that attempts to convert service providers into fiduciaries.
412(e)(3) Plans and Annuities
A 412(e)(3) plan is a tax-qualified, defined benefit pension plan that is funded with either annuities or a combination of annuities and life insurance. These sorts of plans are most often funded through annuities, and those annuities have come to be known as 412(e)(3) annuities, because of the section of the Internal Revenue Code that authorizes this sort of plan. Such 412(e)(3) plans are normally marketed to small businesses as vehicles that can provide large income tax deductions in connection with the establishment or contin
Our team of experienced consulting "tax attorneys", CPAs, and "insurance experts" specializing in 412i" and "419 "IRS audits" that resulted from plans you sold to your clients, mainly "419 plans", "412i plans", "captive insurance" plans and "Section 79" plans as well as other similar "employee benefit plans" or "welfare benefit plans" that the IRS is targeting as "abusive tax shelters".
Our firm has been successful in "defending life insurance agents" and "material advisors" who have participated in the sale of these "benefit plans".
If you signed a return or participated in the sale of these "welfare benefit plans", you are probably a "material advisor" and subject to huge "IRS penalties and interest". No "Form 8886" or "Form 8918" that we have reviewed for new clients has been properly prepared, which leaves the "material advisor" subject to the $200,000 "IRS penalty".
We fight for our clients to defend against the $200,000 IRS "6707A penalty" by providing "expert witness testimony". Lance's side has never lost a case!
ReplyDeleteWhile captive insurance plans are legitimate for large corporations, they are usually not legitimate for small business owners as a way to obtain a tax deduction. I have not yet seen a legitimate Section 79 plan. Recently, I have sent some of the plan promoters’ materials over to my IRS contacts who were very interested in receiving them. Some of my associates are already trying to help defend some unsu
google lance or www.taxaudit419.com
Abusive Insurance and Retirement Plans
ReplyDeleteSingle-employer section 419 welfare benefit plans are the latest incarnation in insurance deductions the IRS deems abusive.
by Lance Wallach
Parts of this article are from the AICPA CPE self-study course Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots, by Sid Kess, authored by Lance Wallach.
Many of the listed transactions that can get your clients into trouble with the IRS are exotic shelters that relatively few practitioners ever encounter. When was the last time you saw someone file a return as a Guamanian trust (Notice 2000-61)? On the other hand, a few listed transactions concern relatively common employee benefit plans the IRS has deemed tax-avoidance schemes or otherwise abusive. Perhaps some of the most likely to crop up, especially in small business returns, are arrangements purporting to allow deductibility of premiums paid for life insurance under a welfare benefit plan.
Abusive Insurance and Retirement Plans
ReplyDeleteSingle-employer section 419 welfare benefit plans are the latest incarnation in insurance deductions the IRS deems abusive.
by Lance Wallach
Parts of this article are from the AICPA CPE self-study course Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots, by Sid Kess, authored by Lance Wallach.
Many of the listed transactions that can get your clients into trouble with the IRS are exotic shelters that relatively few practitioners ever encounter. When was the last time you saw someone file a return as a Guamanian trust (Notice 2000-61)? On the other hand, a few listed transactions concern relatively common employee benefit plans the IRS has deemed tax-avoidance schemes or otherwise abusive. Perhaps some of the most likely to crop up, especially in small business returns, are arrangements purporting to allow deductibility of premiums paid for life insurance under a welfare benefit plan.
Abusive Insurance and Retirement Plans
ReplyDeleteSingle-employer section 419 welfare benefit plans are the latest incarnation in insurance deductions the IRS deems abusive.
by Lance Wallach
Parts of this article are from the AICPA CPE self-study course Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots, by Sid Kess, authored by Lance Wallach.
Many of the listed transactions that can get your clients into trouble with the IRS are exotic shelters that relatively few practitioners ever encounter. When was the last time you saw someone file a return as a Guamanian trust (Notice 2000-61)? On the other hand, a few listed transactions concern relatively common employee benefit plans the IRS has deemed tax-avoidance schemes or otherwise abusive. Perhaps some of the most likely to crop up, especially in small business returns, are arrange
Abusive Insurance and Retirement Plans
ReplyDeleteSingle-employer section 419 welfare benefit plans are the latest incarnation in insurance deductions the IRS deems abusive.
by Lance Wallach
Parts of this article are from the AICPA CPE self-study course Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots, by Sid Kess, authored by Lance Wallach.
Many of the listed transactions that can get your clients into trouble with the IRS are exotic shelters that relatively few practitioners ever encounter. When was the last time you saw someone file a return as a Guamanian trust (Notice 2000-61)? On the other hand, a few listed transactions concern relatively common employee benefit plans the IRS has deemed tax-avoidance schemes or
Lance Wallach | LinkedIn
ReplyDeletewww.linkedin.com/in/lancewallach
Greater New York City Area - director at taxaudit419.com
View Lance Wallach's professional profile on LinkedIn. ... Lance Wallach Consulting and Expert Witness - 419e, 412i, 6707A, IRS 8886 forms, Section 79,.
You shared this on Google+
IRS Secrets You Should Know by Lance Wallach - YouTube
► 0:54► 0:54
www.youtube.com/watch?v...
YouTube
May 18, 2012 - Uploaded by Lance Wallach
Get IRS Secrets You Should Know here: http://www.tinyurl.com/LWIRSBook My name is Lance Wallach and I ...
More by Lance Wallach - in 57 Google+ circles
IRS Audits Focus on Captive Insurance Plans - Lance Wallach
www.lancewallach.com/employeeretirementplan.html
Benistar, SADI Trust,Beta 419,Millennium Plan,Bisys, Creative Services Group,Sterling Benefit Plan, Compass 419,Niche 419,CRESP,Sea Nine Veba, American ...
You shared this on Google+
Material Advisors & 419 Plans Litigation
ReplyDelete412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.
Friday, November 1, 2013
Class Action Challenges Propriety of 412(e)(3) Annuities. Lance Wallach, expert witness.
On August 1, 2012, a putative class action lawsuit was filed in the District of Connecticut challenging the propriety of certain insurance contracts used to fund defined benefit plans described in section 412(e)(3) of the Internal Revenue Code. U.S. Telemanagement, Inc. v. Fidelity Security Life Insurance Co. et al., No. 3:12-cv-1110 JBA (D. Conn.).
Because we perceive that the complaint is attacking the appropriateness of the product, as well as the specifics of the product that the named defendant sold, it is a lawsuit that potentially could have industry-wide implications. In addition, as plaintiffs in some of the ERISA revenue-sharing lawsuits have attempted to do, the complaint alleges that the insurance company that sold the annuities acted as an ERISA fiduciary of the plans. This lawsuit thus extends the attack on insurance companies, as seen in the revenue-sharing class actions, that attempts to convert service providers into fiduciaries.
412(e)(3) Plans and Annuities
A 412(e)(3) plan is a tax-qualified, defined benefit pension plan that is funded with either annuities or a combination of annuities and life insurance. These sorts of plans are most often funded through annuities, and those annuities have come to be known as 412(e)(3) annuities, because of the section of the Internal Revenue Code that authorizes this sort of plan. Such 412(e)(3) plans are normally marketed to small businesses as vehicles that can provide large income tax deductions in connection with the establishment or contin
ReplyDeleteFollow me on
Copyright (C) 2010 - Lance Wallach
Our team of experienced consulting "tax attorneys", CPAs, and "insurance experts" specializing in 412i" and "419 "IRS
audits" that resulted from plans you sold to your clients, mainly "419 plans", "412i plans", "captive insurance" plans
and "Section 79" plans as well as other similar "employee benefit plans" or "welfare benefit plans" that the IRS is
targeting as "abusive tax shelters".
Our firm has been successful in "defending life insurance agents" and "material advisors" who have participated in
the sale of these "benefit plans".
If you signed a return or participated in the sale of these "welfare benefit plans", you are probably a "material
advisor" and subject to huge "IRS penalties and interest". No "Form 8886" or "Form 8918" that we have reviewed for
new clients has been properly prepared, which leaves the "material advisor" subject to the $200,000 "IRS penalty".
We fight for our clients to defend against the $200,000 IRS "6707A penalty" by providing "expert witness
testimony". Lance's side has never lost a case!