IRS Auditing Many 412(i) Plans - Lance Wallach

IRS Auditing Many 412(i) Plans - Lance WallachRevenue Ruling 2004-20 - Abusive Transactions Involving Insurance Policies in IRC 412(i) Retirement Plans (certain arrangements in which an employer deducts contributions to a qualified pension plan for premiums on life insurance contracts that provide for death benefits in excess of the participant’s death benefit, where under the terms of the plan, the balance of the death benefit proceeds revert to the plan as a return on investment) (identified as “listed transactions” on February 13, 2004)). See also Rev. Rul. 2004-21, 2004-10 I.R.B. 544, §§ 1.79-1(d)(3), 1.83-3(e) and 1.402(a)-1(a)(1) and (2) of the proposed Income Tax Regulations, and Rev. Proc. 2004-16, 2004-10 I.R.B. 559;

• Revenue Ruling 2004-21
• Proposed Regulation 126967-03
• Revenue Procedure 2004-16
• News Release IR-2004-21