IRS tax relief firm, Lance Wallach, speaking Lance Wallach showcases his expert knowledge in IRS tax relief.
RAMESH SARVA: SARVA
RAMESH SARVA: SARVA: Defendants have also directly and indirectly promoted the VEBA plan scheme to prospective participants. Sarva for his part has been marketin...
WebCPAs "reflecting the tax consequences of the strategy", it could be argued that continued benefit from a tax deferral for a previous tax deduction is within the contemplation of a "tax consequence" of the plan strategy. Also, many taxpayers who no longer make contributions or claim tax deductions continue to pay administrative fees. Sometimes, money is taken from the plan to pay premiums to keep life insurance policies in force. In these ways, it could be argued that these taxpayers are still "contributing", and thus still must file Form 8886.
It is clear that the extent to which a taxpayer benefits from the transaction depends on the purpose of a particular transaction as described in the published guidance that caused such transaction to be a listed transaction. Revenue Ruling 2004-20 which classifies 419(e) transactions, appears to be concerned with the employer's contribution/deduction amount rather than the continued deferral of the income in previous years. This language may provide the taxpayer with a solid argument in the event of an audit.
Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters. He writes about 412(i), 419, and captive insurance plans. He speaks at more than ten conventions annually, writes for over fifty publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Pubic Radio's All Things Considered, and others. Lance has written numerous books including 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. He does expert witness testimony and has never lost a case. Contact him at 516.938.5007, wallachinc@gmail.com or visit www.taxaudit419.com or www.taxlibrary. us.
The information provided herein is not intended as legal, accounting, financial or any other type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.
412i-419 Plans: RAMESH SARVA: SARVA 412i-419 Plans: RAMESH SARVA: SARVA: RAMESH SARVA: SARVA : Defendants have also directly and indirectly promoted the VEBA plan scheme to prospective participants. Sarva for his
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https://plus.google.com/.../posts/UqB9WPjmexy Lance Wallach Mar 7, 2014 - RAMESH SARVA: Sarva- More You Should Know rameshsarvaveba.blogspot.com/2014/.../sarva-more-you-should-know.ht... Tuesday, January 7, 2014 ... Sarva ...
Ramesh Sarva CPA PC - Forest Hills - Forest Hills, NY | Yelp www.yelp.com › Financial Services › Tax Services Yelp, Inc. Ramesh Sarva CPA PC Forest Hills reviews by real people. Yelp is a fun and easy way to find, recommend and talk about what's great and not so great in Forest ...
WebCPAs "reflecting the tax consequences of the strategy", it could be argued that
ReplyDeletecontinued benefit from a tax deferral for a previous tax deduction is within the contemplation
of a "tax consequence" of the plan strategy. Also, many taxpayers who no longer make
contributions or claim tax deductions continue to pay administrative fees. Sometimes,
money is taken from the plan to pay premiums to keep life insurance policies in force. In
these ways, it could be argued that these taxpayers are still "contributing", and thus still
must file Form 8886.
It is clear that the extent to which a taxpayer benefits from the transaction depends on the
purpose of a particular transaction as described in the published guidance that caused such
transaction to be a listed transaction. Revenue Ruling 2004-20 which classifies 419(e)
transactions, appears to be concerned with the employer's contribution/deduction amount
rather than the continued deferral of the income in previous years. This language may
provide the taxpayer with a solid argument in the event of an audit.
Lance Wallach, National Society of Accountants Speaker of the Year and member of the
AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, financial
and estate planning, and abusive tax shelters. He writes about 412(i), 419, and captive
insurance plans. He speaks at more than ten conventions annually, writes for over fifty
publications, is quoted regularly in the press and has been featured on television and radio
financial talk shows including NBC, National Pubic Radio's All Things Considered, and
others. Lance has written numerous books including 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. He does expert witness testimony and has never lost a case. Contact
him at 516.938.5007, wallachinc@gmail.com or visit www.taxaudit419.com or www.taxlibrary.
us.
The information provided herein is not intended as legal, accounting, financial or any
other type of advice for any specific individual or other entity. You should contact an
appropriate professional for any such advice.
412i-419 Plans: RAMESH SARVA: SARVA
ReplyDelete412i-419 Plans: RAMESH SARVA: SARVA: RAMESH SARVA: SARVA : Defendants have also directly and indirectly promoted the VEBA plan scheme to prospective participants. Sarva for his
...
Search Results RAMESH SARVA: Sarva- More You Should Know ...
https://plus.google.com/.../posts/UqB9WPjmexy
Lance Wallach
Mar 7, 2014 - RAMESH SARVA: Sarva- More You Should Know rameshsarvaveba.blogspot.com/2014/.../sarva-more-you-should-know.ht... Tuesday, January 7, 2014 ... Sarva ...
Ramesh Sarva CPA PC - Forest Hills - Forest Hills, NY | Yelp
www.yelp.com › Financial Services › Tax Services
Yelp, Inc.
Ramesh Sarva CPA PC Forest Hills reviews by real people. Yelp is a fun and easy way to find, recommend and talk about what's great and not so great in Forest ...