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
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ReplyDeleteIRS Audits 419, 412i, Captive Insurance Plans With Life Insurance, and Section 79 Scams
Companies should carefully evaluate proposed investments in plans such as the Benistar Plan. The claimed deductions will not be available, and penalties will be assessed for lack of disclosure if the investment is similar to the investments described in Notice 95-34. In addition, under IRC 6707A, IRS fines participants a large amount of money for not properly disclosing their participation in listed, reportable or similar transactions; an issue that was not before the Tax Court in either Curcio or McGehee. The disclosure needs to be made for every year the participant is in a plan. The forms need to be properly filed even for years that no contributions are made. I have received numerous calls from participants who did disclose and still got fined because the forms were not filled in properly. A plan administrator told me that he assisted hundreds of his participants file forms, and they still all received very large IRS fines for not properly filling in the forms.
IRS has been attacking all 419 welfare benefit plans, many 4
Expert Witness Directoryching professionals, Wallach is a frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters. He is also a featured writer and has been interviewed on television and financial talk shows including NBC, National Public Radio’s All Things Considered and others. Lance authored 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.
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While every effort has been made to ensure the accuracy of this publication, it is not intended to provide legal advice as individual situations will differ and should be discussed with an expert and/or lawyer. For specific technical or legal advice on the information provided and related topics, please contact the author.
ReplyDelete419_412i Plan Plan Abuses
412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.419 Plan, 412i Plan
Saturday, January 24, 2015
IRS Penalties, Audits, Benefit Plans 419e 412i
Posted by Lance Wallach at 11:56 AM
Labels: 412(i), 412i Benefit Plan, 419 Plans, IRS, Lance wallach, Lance Wallach Expert Witness, Lance Wallach Expert Witness
4 comments:
Lance WallachJanuary 27, 2015 at 10:59 AM
The expert on IRS audits of 419e and 412i plans, 6707A, listed and reportable transactions,Section 79, captive insurance and abusive tax shelters
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Lance WallachJanuary 27, 2015 at 11:00 AM
The expert on IRS audits of 419e and 412i plans, 6707A, listed and reportable transactions,Section 79, captive insurance and abusive tax shelters
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Lance WallachJanuary 27, 2015 at 11:00 AM
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