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Wednesday, April 24, 2024

MSCPA -IRS Attacks Biz Owners 419, 412, Section 79 Lance Wallach

MSCPA -IRS Attacks Biz Owners 419, 412, Section 79 Lance Wallach

12 comments:


  1. Section 79 Plans
    412i, 419e plans litigation and IRS Audit Experts for abusive insurance reportable or listed transactions by the IRS,Section 79, Section 79 Lawsuits,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,Section 79 Audits,412i Problems,412i problems, Expert Witness Lance Wallach,412i Help,419 Help, Section 79 problem, Section 79 Life Insurance,

    Wednesday, January 8, 2014

    WHAT IS A SECTION 79 PLAN?
    Section 79 plans are commonly known for the $50,000 free term life insurance they can provide for employees. Less commonly known is that Section 79 plans can also provide permanent life insurance. These plans are employee benefit plans established under Section 79 of the Internal Revenue Code. Section 79 plans are non-qualified plans but they are tax-deductible plans for the adopting employer.
    WHAT ARE THE BENEFITS OF A SECTION 79 PLAN?
    Section 79 plans provide life insurance benefits for employees paid for by the employer. The life premiums paid are 100% tax-deductible to the business. The "economic benefit" of the life insurance is reportable as taxable income for the insured employee. Only life insurance in excess of $50,000 is reportable. The "economic benefit" is determined using the rates under Table I ( Reg. §1.79-3(d)(2)). When permanent insurance is used the reportable economic benefit can be as little as 60% of the actual premium paid and deducted. This can provide a tax-advantaged way to purchase personal life insurance.
    CAN ANY BUSINESS ADOPT A SECTION 79 PLAN?
    Section 79 plans are only for employees. Self-employed individuals, partners and owners of S corporations are not employees. For an owner to participate the sponsoring employer must be a C Corporation.
    MUST EVERY EMPLOYEE BE INCLUDED IN THE PLAN?
    Non-discrimination rules do apply. 70% of all full time employees must benefit, or 85% of participants must be non-key employees. All participants must be offered the same type and amount of benefits. Special rules apply for companies with less than ten employees.
    WHAT OPTIONS ARE TYPICALLY OFFERED IN A SECTION 79 PLAN THAT INCLUDES PERMANENT INSURANCE?
    Typically, employees are offered three options. (1) Permanent life insurance with a death benefit that is a multiple of salary, (2) term insurance with a death benefit that is a multiple of salary, and (3) $50,000 group term insurance. The multiple of salary offered is usually defined by how much insurance the business owner wants for him or herself. Everyone will be offered the same multiple of salary. Option 1, permanent insurance, will produce the largest reportable economic benefit added to the taxable income of the employee, Option 2 will provide a significantly lower reportable economic benefit added to the taxable income of the employee, and Option 3 will result in no economic benefit added to the employee's taxable income.
    These plans are sold so insurance agents can make commissions.

    ReplyDelete
    Replies

    1. Lance Wallach helps with 419 problems. 412i 419 abusive tax shelters IRS audits, lawsuits, Lance Wallach will help www.vebaplan.com
      419, 412i, IRS audits, Lance Wallach, Google him helps, The following had something to do with this.
      Dennis Cunning Steve Toth Randall Smith Paul Kaplan Herb Green Casey Hermansen
      Larry Bell Scott Ridge Judy Carsrud Jeffrey Glasberg Herb McDowel
      Greg Roper Joseph Donnelly
      Norm Bevan Michael Sonnenberg
      Dan Carpenter Anthony Fakouri
      Steve Burgess
      Robin Weingast
      IRS audits 419 412i captive insurance and section 79 plans. Lance Wallach will help you.

      IRS audits section 79 419 412i plans. www.lancewallach.com for help
      IRS raids, Niche, Robin Weingast, Lance Wallach helps, Sadi trust, grist Mill trust, nova 419 welfare benefit plan problems and how Lance Wallach helps.www.vebaplan.com for more help. Sea Nine VEBA, 419, 412i, IRS audits,Sea Nine VEBA, Grist Mill Trust are all audited by the IRS and people in them probably need help.
      Sea Nine VEBA, 419,412i are all IRS audit targets. Lance Wallach can help, www.tazaudit419.com
      419, 412i, IRS audits, Lance Wallach, Google him helps, The following had something to do with this. Author to write about these problems.
      Dennis Cunning Steve Toth Randall Smith Paul Kaplan Herb Green Casey Hermansen
      Larry Bell Scott Ridge Judy Carsrud Jeffrey Glasberg Herb McDowel
      Greg Roper Joseph Donnelly
      Norm Bevan Michael Sonnenberg
      Dan Carpenter Anthony Fakouri
      Steve Burgess
      Robin Weingast
      "SADI Trust" Lance Wallach will help fix the problems that people have that are or were in the plans.
      "Professional Benefits Trust" PBI

      "Sea Nine Veba"
      Bisys
      The "Beta Plan"
      The "Millennium Plan"

      Niche
      The "Ridge Plan"

      The "Grist Mill Trust"
      The "Compass Welfare Benefit Plan"
      "Section 79 Plans"
      "Captive Insurance"
      and other similar "412i retirement plans" and "419 welfare benefit plans

      Lance Wallach, www.taxaudit419.com will help you with these problems and more like section 79, captive insurance lawsuits and IRS audits. People in the section 79 plans 419 welfare benefit plans captive insurance and 412i pension plans are getting audited by the IRS and then they sue. Google Lance Wallach for help with this. If you need help Lance Wallach as an expert witness has never lost a case. You need help NOW.

      Customers of James Cunningham d/b/a Cunningham Financial or CFG Consulting LLC? We want to speak with you!
      IRS audits and lawsuits result from 419 412i captive insurance and section 79 plans. As an expert witness Lance Wallach has never lost a case.

      Delete
    2. Section 79 Plans
      Expert on Section 79 Plans, 419 Plans, and 412i Plans. Providing insight on IRS audit defense, listed transactions, and more.
      at 8:10 AM No comments:

      Delete
    3. Section 79 Plans
      Expert on Section 79 Plans, 419 Plans, and 412i Plans. Providing insight on IRS audit defense, listed transactions, and more.
      at 8:10 AM No comments:

      Delete

    4. The Offices of Lance Wallach :
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      Lance Wallach,
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      The Lance Wallach advantage is credibility, experience & trust !!

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      Copyright (C) 2009 Lance Wallach
      All rights reserved

      Lance Wallach, Managing Director, is the nation's
      leading expert on life insurance, annuities,
      retirement & financial planning for business
      executives, sports figures, entertainers, affluent
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      Delete

    5. The Offices of Lance Wallach :
      "America's leading Financial
      Services firm "(TM)
      Lance Wallach,
      Managing Director

      Financial Planning
      Divison

      Call us today:
      516-938-5007

      Email us at:
      LanWalla@aol.com
      The Lance Wallach advantage is credibility, experience & trust !!

      Many advisory firms offer financial planning and investment services,
      but the difference is that Lance Wallach wrote the books on Life
      Insurance, Financial & Estate planning that the other consultants
      learned from!

      If you want to sleep soundly at night, don't go to the students for your
      financial answers, go to the one who teaches them, Lance Wallach!

      For the past 25 years, successful businesses and individuals have
      turned to Lance Wallach and his team for assistance, and they are
      glad they did!
      Life Insurance & Financial Planning

      When you choose the
      Lance Wallach team, you
      are on the winning team !
      Copyright (C) 2009 Lance Wallach
      All rights reserved

      Lance Wallach, Managing Director, is the nation's
      leading expert on life insurance, annuities,
      retirement & financial planning for business
      executives, sports figures, entertainers, affluent
      families and successful entrepreneurs.

      Mr. Wallach is a member of the AICPA faculty of
      teaching professionals, a frequent keynote speaker
      at business conventions, a best selling financial
      author, and a renowned national financial expert in
      many court cases.

      Some of Mr. Wallach best selling financial & law
      books are:

      * "Wealth Preservation Planning" by the National
      Society of Accountants

      Delete

  2. The Offices of Lance Wallach :
    America's leading Financial
    Services firm "(TM)
    The Lance Wallach advantage is credibility, experience & trust !!

    Many advisory firms offer financial planning and investment services, but the difference is
    that Lance Wallach wrote the books on Life Insurance, Financial & Estate planning that the
    other consultants learned from!

    If you want to sleep soundly at night, don't go to the students for your financial answers, go
    to the one who teaches them, Lance Wallach!

    For the past 25 years, successful businesses and individuals have turned to Lance Wallach
    and his team for assistance, and they are glad they did!
    Winning Team
    When you choose the
    Lance Wallach team, you
    are on the winning team !
    Lance Wallach Managing Director
    Lance Wallach, Managing Director, is the nations leading expert on life insurance, annuities,
    retirement & financial planning for business executives, sports figures, entertainers, affluent families
    and successful entrepreneurs.

    Mr. Wallach is a member of the AICPA faculty of teaching professionals, a frequent keynote speaker
    at business conventions, a best selling financial author, and a renowned national financial expert in
    many court cases.

    Some of Mr. Wallach best selling financial & law books are:

    * "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."

    ReplyDelete
  3. 419_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

    Wednesday, January 7, 2015
    Insurance Agents: Help for those who sold 419 and 412i plans.
    Insurance Agents: Help for those who sold 419 and 412i plans.
    Posted by Lance Wallach at 11:30 AM
    Labels: 412, 412(i), 412i Benefit Plan, 419 Plans, Lance Wallach Expert Witness, Lance Wallach Expert Witness
    1 comment:

    Lance WallachJanuary 14, 2015 at 7:46 AM
    Toolbox for Finance Topics Tax Blogs
    IRS 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

    ReplyDelete

  4. 419_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

    Wednesday, August 13, 2014
    IRS Clarifies Legality of 419(e) Plans
    IRS Clarifies Legality of 419(e) Plans
    Posted by Lance Wallach at 12:04 PM
    Labels: 412, 412(i), 419 Plan, 419 Plans, 419 Planshelters
    6 comments:

    Lance WallachSeptember 29, 2014 at 11:05 AM
    Copyright (C) 2014

    ROBIN S. WEINGAST & ASSOCIATES,
    INC., ROBIN S. WEINGAST, DESIGNS
    FOR FINANCE, INC., and CAPITAL
    ONE, N.A. as successor to NORTH
    FORK BANK AND TRUST CO., and
    POINTE BENEFIT CONSULTANTS,
    LLC.,

    Defendants.


    DENNIS M. CAVANAUGH, U.S.D.J.

    This matter comes before the Court upon motions by Defendants Robin S. Weingast
    &
    Associates, Inc. and Robin S. Weingast (collectively the “Weingast Defendants”)
    (ECF No. 24),
    Defendant Designs for Finance, Inc. (“Designs”)(ECF No. 27), Defendant
    Pointe Benefit
    Consultants, LLC (“Pointe Benefit”)(ECF No. 29), and Defendant Capital One, N.A.
    (“Capitol
    One”)(ECF No. 31) to dismiss Plaintiffs Jeffrey Rapaport M.D., P.A. (“JRMDPA”),
    Jeffrey
    Rapaport (“Rapaport”), and Amanda Rapaport’s (collectively “Plaintiffs”) Complaint in
    this action
    pursuant to FED. R. CIV. P. 12(b)(6). Pursuant to FED. R. CIV. P. 78, no oral
    argument was heard.
    After considering the submissions of the parties, it is the decision of this Court for the
    reasons herein
    expressed that the motions to dismisssubmitted by Defendants Designs, Pointe
    Benefit, and Capital
    One are granted and the motion to dismiss by the Weingast Defendants is denied.

    To Read More:

    http://baritzcolman.com/p

    Reply

    ReplyDelete
  5. 419_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

    Wednesday, January 7, 2015
    Insurance Agents: Help for those who sold 419 and 412i plans.
    Insurance Agents: Help for those who sold 419 and 412i plans.
    Posted by Lance Wallach at 11:30 AM
    Labels: 412, 412(i), 412i Benefit Plan, 419 Plans, Lance Wallach Expert Witness, Lance Wallach Expert Witness
    1 comment:

    Lance WallachJanuary 14, 2015 at 7:46 AM
    Toolbox for Finance Topics Tax Blogs
    IRS 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.

    ReplyDelete
  6. IRS Attacks Business Owners in 419, 412, Section 79 and Captive Insurance Plans Under Section 6707A
    d, 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.

    Contact him at:
    516.938.5007,
    wallachinc@gmail.com, or
    www.taxadvisorexperts.org, or
    www.taxlibrary.us.

    Share This Article With a Friend

    Lance Wallach speaks and writes about benefit plans, and has authored numerous books for the AICPA, Bisk Total tape, and others. He can be reached at (516) 938-5007 or wallachinc@gmail.com. For more articles on this or other subjects, feel free to visit his website at www.taxadvisorexperts.org.

    Lance Wallach, the National Society of Accountants Speaker of the Year, speaks and writes extensively about retirement plans, Circular 230 problems and tax reduction strategies. He speaks at more than 40 conventions annually, writes for over 50 publications, is quoted regularly in the press, and has written numerous best-selling AICPA books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Business Hot Spots. He does extensive expert witness work and has never lost a case. Contact him at 516.938.5007 or visit www.taxadvisorexperts.org.
    Read 3 comments

    ReplyDelete
  7. The Truth About Section 79 Permanent Insurance Plans


    Section 79 plans are a part of the employee benefit section of the Internal Revenue Service code (IRC). This code (IRC code Section 1.79) has been a part of the IRC since it was initially adopted in 1953. The President of the United States at that time was Dwight D. Eisenhower.

    Section 79 permanent insurance plans are sold within the United States by large national life insurance companies, all of whom have internal legal and compliance departments whose role is to ensure that the products sold by those companies are legal and comply with the rules and spirit of the law. Section 79 permanent insurance plans are sold legally in all 50 states of these United States of America. For the protection of consumers, each state has an insurance department that reviews and approves all company and agent licensing and products sold within that state. (see National Association of Insurance Commissioners at this link).

    So, here’s the truth about Section 79 Permanent Insurance Plans:
    • This is a legal insurance product, covered in the IRS Code number 1.79.
    • All group life insurance is covered under this IRS Code. Most governmental agencies, non-profit organizations and large Fortune 1,000 companies have section 79 as an employee benefit.
    • This is not a new code. The IRC 1.79 has been in the code since 1953.
    • All Section 79 products are fully vetted by major national insurance companies, their lawyers and compliance staffs, for sale in all 50 states. These are companies with long and successful histories of selling insurance products in the United States since the mid-1800’s.
    • Every state insurance department has fully vetted these Section 79 products and approved them for sales in their states. These products are legal for sale in all 50 states.
    • Section 79 plans are not “listed transactions.” Here is a list of all listed transactions according to the IRS – http://www.irs.gov/Businesses/Corporations/Listed-Transactions---LB&I-Tier-I-Issues

    There is no need to fear the innuendo of an internet spammer. For REAL information about Section 79 plans, contact Business Planning Group at (888)545-2205 or visit our website at BusinessPlanningGroup.com/truth .

    ReplyDelete