Expert Witness and 419 Plans Litigation - IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS
Expert Witness and 419 Plans Litigation - IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS
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ReplyDeleteHome > Business > Operations > No Shelter Here: Beware of These Insurance Plans
OPERATIONS
Posted on: September 16, 2011 2
2
0
5
No Shelter Here: Beware of These Insurance Plans
Backlash on too-good-to-be-true insurance plan
By Lance Wallach
During the past few years, the Internal Revenue Service (IRS) has fined many business owners hundreds of thousands of dollars for participating in several particular types of insurance plans.
The 412(i), 419, captive insurance, and section 79 plans were marketed as a way for small-business owners to set up retirement, welfare benefit plans, or other tax-deductible programs while leveraging huge tax savings, but the IRS put most of them on a list of abusive tax shelters, listed transactions, or similar transactions, etc., and has more recently focused audits on them. Many accountants are unaware of the issues surrounding these plans, and many big-name insurance companies are still encouraging participation in them.
Seems Attractive
The plans are costly up-front, but your money builds over time, and there’s a large payout if the money is removed before death. While many business owners have retirement plans, they also must care for
Get the latest industry news SubscribeNewsletter
ReplyDeleteHome > Business > Operations > No Shelter Here: Beware of These Insurance Plans
OPERATIONS
Posted on: September 16, 2011 2
2
0
5
No Shelter Here: Beware of These Insurance Plans
Backlash on too-good-to-be-true insurance plan
By Lance Wallach
During the past few years, the Internal Revenue Service (IRS) has fined many business owners hundreds of thousands of dollars for participating in several particular types of insurance plans.
The 412(i), 419, captive insurance, and section 79 plans were marketed as a way for small-business owners to set up retirement, welfare benefit plans, or other tax-deductible programs while leveraging huge tax savings, but the IRS put most of them on a list of abusive tax shelters, listed transactions, or similar transactions, etc., and has more recently focused audits on them. Many accountants are unaware of the issues surrounding these plans, and many big-name insurance companies are still encouraging participation in them.
Seems Attractive
The plans are costly up-front, but your money builds over time, and there’s a large payout if the money is removed before death. While many business owners have retirement plans, they also must care for
Expert Witness & 419 Plans Litigation
ReplyDelete412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.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,
Monday, November 25, 2013
419 Welfare Benefit Plans. Lance Wallach, expert witness.
A view from a former IRS Agent, CPA, College Professor - Sam Susser - Welfare Benefit Plans (WBP), also known as Welfare Benefit Trusts and Welfare Benefit Funds are vehicles by which employers may offer their employees and retirees with certain types of insurance coverage (e.g., life insurance, health insurance, disability insurance, and long-term care), as well as other benefits such as severance payments and educational funding.
If properly designed and in compliance with IRC sections 419 and 419A, WBPs offer employers with a valid tax deduction. However, as is the case with many plans that offer opportunities for deductibility, some WBPs fail to comply with Code standards, invite abuse, and otherwise are used inappropriately as a basis to reduce taxable income.
It is, therefore, not surprising that the Internal Revenue Service (IRS) has targeted WBP, designating many such plans as “listed transactions.” The IRS’ attack arsenal includes, but is not limited to: Notice 2007-83 (where the IRS intends to challenge claimed tax benefits meeting the definition of a “listed transaction”
Expert Witness & 419 Plans Litigation
ReplyDelete412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.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,
Monday, November 25, 2013
419 Welfare Benefit Plans. Lance Wallach, expert witness.
A view from a former IRS Agent, CPA, College Professor - Sam Susser - Welfare Benefit Plans (WBP), also known as Welfare Benefit Trusts and Welfare Benefit Funds are vehicles by which employers may offer their employees and retirees with certain types of insurance coverage (e.g., life insurance, health insurance, disability insurance, and long-term care), as well as other benefits such as severance payments and educational funding.
If properly designed and in compliance with IRC sections 419 and 419A, WBPs offer employers with a valid tax deduction. However, as is the case with many plans that offer opportunities for deductibility, some WBPs fail to comply with Code standards, invite abuse, and otherwise are used inappropriately as a basis to reduce taxable income.
It is, therefore, not surprising that the Internal Revenue Service (IRS) has targeted WBP, designating many such plans as “listed transactions.” The IRS’ attack arsenal includes, but is not limited to: Notice 2007-83 (where the IRS intends to challenge claimed tax benefits meeting the definition of a “listed transaction”
ReplyDeleteExpert Witness & 419 Plans Litigation
412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.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,
Tuesday, October 21, 2014
Lance Wallach - 419 Plan Help, Expert Witness Testimony, Expert Witness Services
Lance Wallach - 419 Plan Help, Expert Witness Testimony, Expert Witness Services
Posted by Lance Wallach at 7:38 AM
Labels: 412i, 419, 419 Plans, abusive tax shelters, captive insurance, Form 8886, lance wallach, Lance Wallach Expert Witness, welfare benefit plans
ReplyDeleteExpert Witness & 419 Plans Litigation
412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.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,
Tuesday, October 21, 2014
Lance Wallach - 419 Plan Help, Expert Witness Testimony, Expert Witness Services
Lance Wallach - 419 Plan Help, Expert Witness Testimony, Expert Witness Services
Posted by Lance Wallach at 7:38 AM
Labels: 412i, 419, 419 Plans, abusive tax shelters, captive insurance, Form 8886, lance wallach, Lance Wallach Expert Witness, welfare benefit plans