Our team of experienced consulting "tax attorneys",
CPAs, and "insurance experts" specializing in Beta Plans
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!
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!
www.vebaplan.com for help
ReplyDeleteThursday, January 23, 2014
How to Avoid IRS Fines for You and Your Clients
FROM THE OCTOBER 01, 2010 ISSUE OF AGENT’S SALES JOURNAL •
BY LANCE WALLACH
Beware: The IRS is cracking down on small-business owners who participate in tax-reduction insurance plans sold by insurance agents, including defined benefit retirement plans, IRAs, and even 401(k) plans with life insurance. In these cases, the business owner is motivated by a large tax deduction; the insurance agent is motivated by a substantial commission.
A few years ago, I testified as an expert witness in a case in which a physician was in an abusive 401(k) plan with life insurance. It had a so-called "springing cash value policy" in it. The IRS calls plans with these types of policies "listed transactions." The judge called the insurance agent "a crook."
If your client was currently is in a 412(i), 419, captive insurance, or Section 79 plan, they may be in big trouble. Accountants who signed a tax return for a client in one of these plans may be what the IRS calls a "material advisor" and subject to a maximum $200,000 fine.
www.taxaudit419.com for beta plan help or google lance wallach who can also help with beta and other 419 plans and look at some below
ReplyDelete"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 Walrry 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 "millenium Plan"
Benistar
Niche
The "Ridge Plan"
The "Grist Mill Trust"
The "Compass Welfare Benefit Plan"
"Section 79 Plans"
"Captive Insurance"
ReplyDelete419 Plans Attacked by IRS
________________________________________
By Lance Wallach, CLU, CHFC Abusive Tax Shelter, Listed Transaction, Reportable Transaction Expert Witness
________________________________________
Insurance agents and costs attacked. - Enrolled Agents Journal March*April - For years promoters of life insurance companies and agents have tried to find ways of claiming that the premiums paid by business owners were tax deductible. This allowed them to sell policies at a “discount”.
The problem became especially bad a few years ago with all of the outlandish claims about how §§419A(f)(5) and 419A(f)(6) exempted employers from any tax deduction limits. Many other inaccurate statements were made as well, until the IRS finally put a stop to such assertions by issuing regulations and naming such plans as “potentially abusive tax shelters” (or “listed transactions”) that needed to be disclosed and registered. This appeared to put an end to the scourge of such scurrilous promoters, as such plans began to disappear from the landscape.
And what happened to all the providers that were peddling §§419A(f)(5) and (6) life insurance plans a couple of years ago? We recently found the answer: most of them found a new life as promoters of so-called “419(e)” welfare benefit plans.
We recently reviewed several §419(e) plans, and it appears that many of them are nothing more than recycled §419A(f)(5) and §419A(f)(6) plans.
The “Tax Guide” written by one vendor’s attorney is illustrative: he confuses the difference between a “multi-employer trust” (a Taft-Hartley, collectively-bargained plan), a “multiple-employer trust” (a plan with more than one unrelated employer) and a “10-or-more employer trust” (a plan seeking to comply with IRC §419A(f)(6)).
Background: Section 419 of the Internal Revenue Code
Section 419 was added to the Internal Revenue Code (“IRC”) in 1984 to curb abuses in welfare benefit plan tax deductions. §419(a) does not authorize tax deductions, but provides as follows: “Contributions paid or accrued by an employer to a welfare benefit fund * * * shall not be deductible under this chapter * * *.”. It simply limits the amount that would be deductible under another IRC section to the “qualified cost for the taxable year”. (§419(b))
Section 419(e) of the IRC defines a “welfare ben
more of the article
ReplyDeletenefits.
8. Some vendors permit participation by employees who are self-employed, such as sole proprietors, partners or members of an LLC or LLP taxed as a partnership. This issue was also addressed in the Neonatology case where contributions on behalf of such persons were deemed to be dividends or personal payments rather than welfare benefit plan expenses.
[Note: bona fide employees of an LLC or LLP that has elected to be taxed as a corporation may participate in a plan.]
9. Most of the plans fail under §419 itself. §419(c) limits the current tax deduction to the “qualified cost”, which includes the “qualified direct cost” and additions to a “qualified asset account” (subject to the limits of §419A(b)). Under Regs. §1.419-1T, A-6, “the "qualified direct cost" of a welfare benefit fund for any taxable year * * * is the aggregate amount which would have been allowable as a deduction to the employer for benefits provided by such fund during such year (including insurance coverage for such year) * * *.” “Thus, for example, if a calendar year welfare benefit fund pays an insurance company * * * the full premium for coverage of its current employees under a term * * * insurance policy, * * * only the portion of the premium for coverage during [the year] will be treated as a "qualified direct cost" * * *.” (Italics added)
Most vendors pretend that the whole or universal life insurance premium is an appropriate measurement of c
Specializing in IRS Audit Defense
ReplyDeleteOur team of experienced consulting "tax attorneys", CPAs, and "insurance experts" specializing in Beta Plans 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!
google lance wallach beta plan beta for 419 help
Qualifications and Work History of Lance Wallach
ReplyDeleteEXPERT QUALIFICATIONS, INCLUDING LIST OF PUBLICATIONS AUTHORED WITHIN PRECEDING TEN YEARS
I am a member of the American Institute of Certified Public Accountants (“AICPA”) faculty of teaching professionals and an AICPA course developer, and I have frequently spoken and/or published articles about Section 419 plans. I have also been qualified as an expert witness and have testified in court proceedings about issues relating to Section 419 plans, VEBAS and related plans.
Within the past ten years, I have authored or coauthored the articles, books, and/or other publications as referenced below.
PRIOR EXPERT WITNESS TESTIMONY AT TRIAL AND BY DEPOSITION DURING PRECEDING FOUR YEARS
Trial Testimony as Expert
Date: September 16 and 17, 2008
Litigation: Novick v. Bankers Life, et al.
Court: United States District Court, Eastern District of New York, Central Islip, New York
There was also extensive deposition testimony in this matter in May of 2008, which depositions lasted for two full days.
Trial Testimony as Expert
Date: March 31, 2009
Litigation: Michael Greco, et al, v. Empire Financial Group, Inc., et al
FINRA Arbitration No. 08-01565
Trial Testimony as Expert
Date: June 29, June 30, and July 1, 2009
Litigation: Michael Greco, et al, v. Empire Financial Group, Inc., et al
For beta plan or benistar grist mill nova sadi sea nine veba or other 419 abusive tax shelter help www.vebaplan.com or www.taxaudit419.com for beta plan help. Get your beta money back fight IRS file 8886 sue the ***********
ReplyDeleteLance Wallach, Managing Director, is the
ReplyDeletenation'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