Abusive Tax Shelters & 419 Plans Lawsuits 412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.
Tuesday, March 18, 2014
412i-419 Plans: KENNETH ELLIOT: Sea Nine VEBA Important 412i-419 Plans: KENNETH ELLIOT: Sea Nine VEBA Important: KENNETH ELLIOT: Sea Nine VEBA Important : As of August 23,2013, the IRS has closed audits of 12 Sea Nine VEBA plan-participating taxpayers w...
Internal Revenue Code 6707A and Section 79: Breaking Down the Problem Internal Revenue Code 6707A and Section 79: Breaking Down the Problem Lance Wallach Council Member President, VEBA Plan
April 06,
Premise by Lance WallachThe IRS is fussy about its forms, and people involved in 419 and 412i plans discovered that the hard way. Now the IRS is starting to target Section 79 plans, and business owners are running into the same 6707A issues that the 412i and 419 plan participants had. Knowing this history could help someone considering a Section 79 plan avoid those very major headaches.
Discussion Insurance companies, agents, financial planners, and others have pushed abusive 419 and 412i plans for years. They claimed business owners could obtain large tax deductions. Insurance companies, agents and others earned very large life insurance commissions in the process. Eventually, the IRS cracked down on the unsuspecting business owners. Not only did they lose the tax deductions, but they were also fined and charged penalties and interest.
After the business owner was assessed the fines and lost his tax deduction, the IRS then came back and fined him a huge amount of money for not telling on himself under Internal Revenue Code 6707A. You see, if you participate in a listed or reportable transaction, you must alert the IRS or face a large fine. In essence, you must alert the IRS if you were in a transaction that has the possibility of tax avoidance or evasion. Not only must you file Form 8886 telling on yourself, but the form needs to be filed properly, and done every year that you are in the plan, even if you are no longer making contributions.
I have received hundreds of phone calls from business owners who improperly filed Form 8886, usually with the help of their accountants or the plan promoter. They got the fine for either improperly filing, or for making mistakes on the form. I only know of two people in the entire country who have consistently prepared these forms properly.
In addition, many states also require forms to be filed. For example, if you work in New York State and manage to properly fill out the Federal form, but don’t file the State form, you may still get fined.
Lately, insurance companies, agents, accountants, and others have been selling captive insurance and Section 79 scams. The motivations are exactly the same. They push large tax deductions for business owners. The
The Internal Revenue Service announced today the mailing of a time-limited settlement offer for certain taxpayers under audit who partit these abusive transactions.
Lance Wallach Expert Witness SearchSKIP TO CONTENT LIFE INSURANCE LITIGATION SUPPORT LIFE INSURANCE EXCHANGES PROTECTING CLIENTS… WHAT WE DO RESUME CONTACT US PROTECTING CLIENTS… protecting_book_cover… from Fraud, Incompetence and Scams
Protect your clients — and yourself — from all kinds of financial chicanery and stupidity with this vital new book It doesn’t matter if a financial error was made because of malice or ignorance — the end result is that you lose money. Luckily, you don’t have to sit idly and take it. If you have Protecting Clients from Fraud, Incompetence and Scams , you can identify and avoid the dysfunctional sectors of the financial industry, steer clear of the fallout from the Madoff Era, and guide your clients to real, healthy, sustainable returns. This powerful book Pinpoints dysfunctional sectors within the financial industry and offers advice against frauds and scammers Shows how a team approach to asset management can ward off financial predators Offers practical strategies and tools to combat client risk for Risk and Asset Management Offering insightful information to protect your clients from all sorts of frauds and incompetence, this essential guide equips you with tips and techniques to spot the red flags of fraud and prevent it before it starts.
Abusive Tax Shelters & 419 Plans Lawsuits
ReplyDelete412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.
Tuesday, March 18, 2014
412i-419 Plans: KENNETH ELLIOT: Sea Nine VEBA Important
412i-419 Plans: KENNETH ELLIOT: Sea Nine VEBA Important: KENNETH ELLIOT: Sea Nine VEBA Important : As of August 23,2013, the IRS has closed audits of 12 Sea Nine VEBA plan-participating taxpayers w...
, April 18, 2014
ReplyDeleteInternal Revenue Code 6707A and Section 79: Breaking Down the Problem
Internal Revenue Code 6707A and Section 79: Breaking Down the Problem
Lance Wallach Council Member President, VEBA Plan
April 06,
Premise
by Lance WallachThe IRS is fussy about its forms, and people involved in 419 and 412i plans discovered that the hard way. Now the IRS is starting to target Section 79 plans, and business owners are running into the same 6707A issues that the 412i and 419 plan participants had. Knowing this history could help someone considering a Section 79 plan avoid those very major headaches.
Discussion
Insurance companies, agents, financial planners, and others have pushed abusive 419 and 412i plans for years. They claimed business owners could obtain large tax deductions. Insurance companies, agents and others earned very large life insurance commissions in the process. Eventually, the IRS cracked down on the unsuspecting business owners. Not only did they lose the tax deductions, but they were also fined and charged penalties and interest.
After the business owner was assessed the fines and lost his tax deduction, the IRS then came back and fined him a huge amount of money for not telling on himself under Internal Revenue Code 6707A. You see, if you participate in a listed or reportable transaction, you must alert the IRS or face a large fine. In essence, you must alert the IRS if you were in a transaction that has the possibility of tax avoidance or evasion. Not only must you file Form 8886 telling on yourself, but the form needs to be filed properly, and done every year that you are in the plan, even if you are no longer making contributions.
I have received hundreds of phone calls from business owners who improperly filed Form 8886, usually with the help of their accountants or the plan promoter. They got the fine for either improperly filing, or for making mistakes on the form. I only know of two people in the entire country who have consistently prepared these forms properly.
In addition, many states also require forms to be filed. For example, if you work in New York State and manage to properly fill out the Federal form, but don’t file the State form, you may still get fined.
Lately, insurance companies, agents, accountants, and others have been selling captive insurance and Section 79 scams. The motivations are exactly the same. They push large tax deductions for business owners. The
The Internal Revenue Service announced today the mailing of a time-limited settlement offer for certain taxpayers under audit who partit these abusive transactions.
ReplyDeleteLance Wallach Expert Witness
ReplyDeleteSearchSKIP TO CONTENT
LIFE INSURANCE LITIGATION SUPPORT
LIFE INSURANCE EXCHANGES
PROTECTING CLIENTS… WHAT WE DO RESUME CONTACT US
PROTECTING CLIENTS…
protecting_book_cover… from Fraud, Incompetence and Scams
Protect your clients — and yourself — from all kinds of financial chicanery and stupidity with this vital new book It doesn’t matter if a financial error was made because of malice or ignorance — the end result is that you lose money. Luckily, you don’t have to sit idly and take it. If you have Protecting Clients from Fraud, Incompetence and Scams , you can identify and avoid the dysfunctional sectors of the financial industry, steer clear of the fallout from the Madoff Era, and guide your clients to real, healthy, sustainable returns. This powerful book Pinpoints dysfunctional sectors within the financial industry and offers advice against frauds and scammers Shows how a team approach to asset management can ward off financial predators Offers practical strategies and tools to combat client risk for Risk and Asset Management Offering insightful information to protect your clients from all sorts of frauds and incompetence, this essential guide equips you with tips and techniques to spot the red flags of fraud and prevent it before it starts.