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...



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  1. 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.

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  2. 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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