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View New Content BenefitsLink Message Boards Members Forums BenefitsLink Message Boards → Retirement Plans → Defined Benefit Plans, Including Cash Balance Photo Terminating 412i plan - question Started by jc1457 , Jul 16 2010 09:03 AM
PREV Page 2 of 2 1 2 Please log in to reply 28 replies to this topic #26 Terminating 412i plan - question: post #26 VEBAPLAN Registered User
Registered 96 posts Posted 27 July 2010 - 07:23 AM And thanks to metoo also. But my side has NEVER lost a case. The lawyers must not be as good as MeToo? Why not Google me, and then think again? Lance Wallach Lance Wallach, CLU, ChFC, CIMC, speaks and writes extensively about VEBAs, retirement plans, and tax reduction strategies. He speaks at more than 50 national conventions annually and writes for more than 30 publications. For more information and additional articles on these subjects, visit www.vebaplan.com or call 516-938-5007. #27 Terminating 412i plan - question: post #27 Blinky the 3-eyed Fish Registered User
Sitewide Moderator 3,364 posts Posted 25 April 2012 - 12:38 PM Lance, you are new to this group? Well that's interesting. You might want to investigate VEBAPLAN. He's been using your name in his signature. Maybe you are just looking for a fresh start after VEBAPLAN's postings. Maybe you have Schizophrenia and Lance is the nicer personality. Maybe you have dementia and have forgotten VEBAPLAN.
Anyway, good luck with the "new" you. "What's in the big salad?" "Big lettuce, big carrots, tomatoes like volleyballs." #28 Terminating 412i plan - question: post #28 AndyH Registered User
Sitewide Moderator 3,979 posts Posted 25 April 2012 - 12:47 PM Don't click the new guy's forum link.
My system says "Request blocked by Anti-Virus. It is found to be associated with Malware"
Nice gift from the new guy. #29 Terminating 412i plan - question: post #29 LanceWallach Registered User
Registered 1 posts Posted 25 April 2012 - 12:59 PM Not sure why it would say that. Here's the full link: http://pub33.bravene...o...148&msgid=0
Did You Participate in a 419 Plan, 412i Plan, or Abusive Tax Shelter? You Could Be Fined $200,000 Per Year! He Found A Baby Dying In The Sun. What He Did Next Defied All Odds! (LittleBudha.com) Recommended by We Recommend Ken Kaufman's Blog on Finance and Entrepreneurship Monthly Archives Global Family Monthly Archives Big Data: Can the Regulators Handle the Big Challenge to Big Audit Previewing the PCAOB's Public Meetings on the Auditor's Report - Where Can We Find the Bar? Passing Assets to the Next Generation - Does Fair Mean Equal? "Where Were The Auditors?" -- Addressing the Inevitability of Behavioural Risk From Around The Web Man Busts Best Friend's Wife Cheating & Does the Unexpected (VIDEO) (Stirring Daily) Female MMA Fighter’s “Brutal Arm” (The New Yorker on The Scene) Top 15 Kate Upton Bikini Moments (Fame Focus) The 18 Sexiest Sports Broadcasters That Have Ever Been On Television Are Ranked Here (ViralWorld) First of Two Kansas Girls to Commit Suicide Last Weekend Used a Gun to Kill Herself (People) Recommended by
419, Section 412(i), & Other Abusive Plans by Lance Wallach The IRS has various task forces auditing all section 419, section 412(i), and other plans that tend to be abusive. These plans are ... more Receive the latest blog posts:
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The IRS is aggressively auditing 412(i) plans –- that is, defined benefit pension plans funded exclusively with insurance contracts. It is seeking to curb what it believes to be abuses in the establishment and funding of some of these plans. As a practical matter, most of the targeted practices are found in smaller plans (1 to 15 participants). If the IRS is successful in attacking these practices, taxpayers that established these types of 412(i) plans in the last few years will face substantial taxes and penalties unless they properly present their positions in the audit process.
Over the past several years, the IRS has systematically escalated its challenge to “abusive” 412(i) plans. The chronology:
Beginning in the early 2000s, IRS officials began giving speeches at benefits conferences expressing the Service’s concern that 412(i) plans were being funded in a way that did not meet the letter or the spirit of the Internal Revenue Code. The officials commented that the IRS intended to take steps to prevent misuse of insurance products in qualified plans. The plans which seemed to generate the most IRS attention were those funded exclusively or almost exclusively with life insurance (as opposed to annuities or a mix of life insurance and annuities). This was especially true of plans using policies designed to have low initial cash surrender values and high premium costs for a fixed number of years. The IRS was also concerned about the sale or distribution of these policies from the plans to key employees, where artificially suppressed values were used. In February 2004, the IRS issued 412(i) guidance. The guidance covers: plans that discriminate in favor of the high paid through the types of insurance contracts held by the plan for their benefit; deductibility of premium contributions; and life insurance contract valuation issues. This guidance also placed certain plans on the IRS list of abusive tax transactions -– that is, plans funded with life insurance with a policy death benefit exceeding the permissible legal limits by $100,000 or more. Taxpayers who engage in “listed transactions” are required to report them to the IRS or face substantial penalties ($100,000 in the case of individuals and $200,000 in the case of entities). In addition, “material advisors” to these plans are required to maintain certain records and turn them over to the IRS
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Accounting. Audit and Tax (Forum Locked Forum Locked) CPAnet Forum : Accounting. Audit and Tax Subject Topic: IRS audits section 79 419 412i CPA fines Post ReplyPost New Topic
Joined: 18 Jul 2012 Location: United States Online Status: Offline Posts: 4 Posted: 18 Jul 2012 at 15:06 | IP Logged Quote Lance Wallach IRS audits section 79 412i 419 plans and fines accountants 100,000 as material advisors for more goole 419 or lance wallach or www.vebaplan.com Back to Top View Lance Wallach's Profile Search for other posts by Lance Wallach
Lance Wallach Newbie Newbie
Joined: 18 Jul 2012 Location: United States Online Status: Offline Posts: 4 Posted: 18 Jul 2012 at 15:07 | IP Logged Quote Lance Wallach Lance Wallach, www.vebaplan.com can help you with the problems of 419 412i and abusive tax shelters. 419, 412i, IRS audits, Lance Wallach, Google him helps, The following had something to do with this. Woman to act in vidio on point needed. 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
Active TopicsActive Topics Display List of Forum MembersMemberlist Search The ForumSearch HelpHelp RegisterRegister LoginLogin
Accounting. Audit and Tax (Forum Locked Forum Locked) CPAnet Forum : Accounting. Audit and Tax Subject Topic: IRS audits section 79 419 412i CPA fines Post ReplyPost New Topic
Joined: 18 Jul 2012 Location: United States Online Status: Offline Posts: 4 Posted: 18 Jul 2012 at 15:06 | IP Logged Quote Lance Wallach IRS audits section 79 412i 419 plans and fines accountants 100,000 as material advisors for more goole 419 or lance wallach or www.vebaplan.com Back to Top View Lance Wallach's Profile Search for other posts by Lance Wallach
Lance Wallach Newbie Newbie
Joined: 18 Jul 2012 Location: United States Online Status: Offline Posts: 4 Posted: 18 Jul 2012 at 15:07 | IP Logged Quote Lance Wallach Lance Wallach, www.vebaplan.com can help you with the problems of 419 412i and abusive tax shelters. 419, 412i, IRS audits, Lance Wallach, Google him helps, The following had something to do with this. Woman to act in vidio on point needed. 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
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Terminating 412i plan - question
Started by jc1457 , Jul 16 2010 09:03 AM
PREV Page 2 of 2 1 2
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28 replies to this topic
#26 Terminating 412i plan - question: post #26 VEBAPLAN
Registered User
Registered
96 posts
Posted 27 July 2010 - 07:23 AM
And thanks to metoo also. But my side has NEVER lost a case. The lawyers must not be as good as MeToo? Why not Google me, and then think again? Lance Wallach
Lance Wallach, CLU, ChFC, CIMC, speaks and writes extensively about VEBAs, retirement plans, and tax reduction strategies. He speaks at more than 50 national conventions annually and writes for more than 30 publications. For more information and additional articles on these subjects, visit www.vebaplan.com or call 516-938-5007.
#27 Terminating 412i plan - question: post #27 Blinky the 3-eyed Fish
Registered User
Sitewide Moderator
3,364 posts
Posted 25 April 2012 - 12:38 PM
Lance, you are new to this group? Well that's interesting. You might want to investigate VEBAPLAN. He's been using your name in his signature. Maybe you are just looking for a fresh start after VEBAPLAN's postings. Maybe you have Schizophrenia and Lance is the nicer personality. Maybe you have dementia and have forgotten VEBAPLAN.
Anyway, good luck with the "new" you.
"What's in the big salad?"
"Big lettuce, big carrots, tomatoes like volleyballs."
#28 Terminating 412i plan - question: post #28 AndyH
Registered User
Sitewide Moderator
3,979 posts
Posted 25 April 2012 - 12:47 PM
Don't click the new guy's forum link.
My system says "Request blocked by Anti-Virus. It is found to be associated with Malware"
Nice gift from the new guy.
#29 Terminating 412i plan - question: post #29 LanceWallach
Registered User
Registered
1 posts
Posted 25 April 2012 - 12:59 PM
Not sure why it would say that. Here's the full link: http://pub33.bravene...o...148&msgid=0
Did You Participate in a 419 Plan, 412i Plan, or Abusive Tax Shelter? You Could Be Fined $200,000 Per Year!
ReplyDeleteHe Found A Baby Dying In The Sun. What He Did Next Defied All Odds!
(LittleBudha.com)
Recommended by
We Recommend
Ken Kaufman's Blog on Finance and Entrepreneurship Monthly Archives
Global Family Monthly Archives
Big Data: Can the Regulators Handle the Big Challenge to Big Audit
Previewing the PCAOB's Public Meetings on the Auditor's Report - Where Can We Find the Bar?
Passing Assets to the Next Generation - Does Fair Mean Equal?
"Where Were The Auditors?" -- Addressing the Inevitability of Behavioural Risk
From Around The Web
Man Busts Best Friend's Wife Cheating & Does the Unexpected (VIDEO) (Stirring Daily)
Female MMA Fighter’s “Brutal Arm” (The New Yorker on The Scene)
Top 15 Kate Upton Bikini Moments (Fame Focus)
The 18 Sexiest Sports Broadcasters That Have Ever Been On Television Are Ranked Here (ViralWorld)
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Recommended by
419, Section 412(i), & Other Abusive Plans
by Lance Wallach
The IRS has various task forces auditing all section 419, section 412(i), and other plans that tend to be abusive. These plans are ... more
Receive the latest blog posts:
Share Your Perspective
Share your professional knowledge and experience with peers. Start a blog on Toolbox for Finance today!
BEGIN NOW
Lance Wallach
ReplyDeleteExtended circles - Dec 8, 2014
IRS Targets 412(i) Plans
The ERISA Audit Bulletin
The IRS is aggressively auditing 412(i) plans –- that is, defined benefit pension plans funded exclusively with insurance contracts. It is seeking to curb what it believes to be abuses in the establishment and funding of some of these plans. As a practical matter, most of the targeted practices are found in smaller plans (1 to 15 participants). If the IRS is successful in attacking these practices, taxpayers that established these types of 412(i) plans in the last few years will face substantial taxes and penalties unless they properly present their positions in the audit process.
Over the past several years, the IRS has systematically escalated its challenge to “abusive” 412(i) plans. The chronology:
Beginning in the early 2000s, IRS officials began giving speeches at benefits conferences expressing the Service’s concern that 412(i) plans were being funded in a way that did not meet the letter or the spirit of the Internal Revenue Code. The officials commented that the IRS intended to take steps to prevent misuse of insurance products in qualified plans. The plans which seemed to generate the most IRS attention were those funded exclusively or almost exclusively with life insurance (as opposed to annuities or a mix of life insurance and annuities). This was especially true of plans using policies designed to have low initial cash surrender values and high premium costs for a fixed number of years. The IRS was also concerned about the sale or distribution of these policies from the plans to key employees, where artificially suppressed values were used.
In February 2004, the IRS issued 412(i) guidance. The guidance covers: plans that discriminate in favor of the high paid through the types of insurance contracts held by the plan for their benefit; deductibility of premium contributions; and life insurance contract valuation issues. This guidance also placed certain plans on the IRS list of abusive tax transactions -– that is, plans funded with life insurance with a policy death benefit exceeding the permissible legal limits by $100,000 or more. Taxpayers who engage in “listed transactions” are required to report them to the IRS or face substantial penalties ($100,000 in the case of individuals and $200,000 in the case of entities). In addition, “material advisors” to these plans are required to maintain certain records and turn them over to the IRS
Active TopicsActive Topics Display List of Forum MembersMemberlist Search The ForumSearch HelpHelp
RegisterRegister LoginLogin
Accounting. Audit and Tax (Forum Locked Forum Locked)
CPAnet Forum : Accounting. Audit and Tax
Subject Topic: IRS audits section 79 419 412i CPA fines Post ReplyPost New Topic
Author
Message << Prev Topic | Next Topic >>
Lance Wallach
Newbie
Newbie
Joined: 18 Jul 2012
Location: United States
Online Status: Offline
Posts: 4
Posted: 18 Jul 2012 at 15:06 | IP Logged Quote Lance Wallach
IRS audits section 79 412i 419 plans and fines accountants
100,000 as material advisors for more goole 419 or lance
wallach or www.vebaplan.com
Back to Top View Lance Wallach's Profile Search for other posts by Lance Wallach
Lance Wallach
Newbie
Newbie
Joined: 18 Jul 2012
Location: United States
Online Status: Offline
Posts: 4
Posted: 18 Jul 2012 at 15:07 | IP Logged Quote Lance Wallach
Lance Wallach, www.vebaplan.com can help you with the
problems of 419 412i and abusive tax shelters.
419, 412i, IRS audits, Lance Wallach, Google him helps,
The following had something to do with this. Woman to act
in vidio on point needed.
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
Active TopicsActive Topics Display List of Forum MembersMemberlist Search The ForumSearch HelpHelp
RegisterRegister LoginLogin
Accounting. Audit and Tax (Forum Locked Forum Locked)
CPAnet Forum : Accounting. Audit and Tax
Subject Topic: IRS audits section 79 419 412i CPA fines Post ReplyPost New Topic
Author
Message << Prev Topic | Next Topic >>
Lance Wallach
Newbie
Newbie
Joined: 18 Jul 2012
Location: United States
Online Status: Offline
Posts: 4
Posted: 18 Jul 2012 at 15:06 | IP Logged Quote Lance Wallach
IRS audits section 79 412i 419 plans and fines accountants
100,000 as material advisors for more goole 419 or lance
wallach or www.vebaplan.com
Back to Top View Lance Wallach's Profile Search for other posts by Lance Wallach
Lance Wallach
Newbie
Newbie
Joined: 18 Jul 2012
Location: United States
Online Status: Offline
Posts: 4
Posted: 18 Jul 2012 at 15:07 | IP Logged Quote Lance Wallach
Lance Wallach, www.vebaplan.com can help you with the
problems of 419 412i and abusive tax shelters.
419, 412i, IRS audits, Lance Wallach, Google him helps,
The following had something to do with this. Woman to act
in vidio on point needed.
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