Showing posts with label IRS. Show all posts
Showing posts with label IRS. Show all posts
If the IRS Contacts You... - HG.org
Keep your mouth shut-take this advice seriously.
If you give the agents any opening, you're dead.
They'll start with soft background questions, but before you know it, will have trapped you. And many questions won't be genuine-that is, the agents already know the answers and are asking only to see if you will lie or confess.
Questions typically asked by agents include:
- Have you reported all of your income?
- Where are your bank accounts and safe deposit boxes?
- Can you tell us about the cars, boats, planes, and real estate that you own?
- What is the procedure for reporting sales in your business?
- Do you keep a lot of cash on hand?
- Who are your business associates?
- Have you traveled out of the country recently?
- Have you or any of your businesses been audited?
Faced with a barrage of questions from trained agents who show up unannounced, most people fall apart. They either blurt out a confession or a transparent lie within five minutes. This gives the Justice Department the rope to hang them with.
Don't Let that happen to you.
Reportable Transactions & 419 Plans Litigation: CJA and associates 419 412i section 79 scam audits...
Reportable Transactions & 419 Plans Litigation: CJA and associates 419 412i section 79 scam audits...: CJA and associates 419 412i section 79 scam audits lawsuitsIn the third case, Harris v. Koresko et al (docket number: 2:09-cv-00988-MAM), the DOL was granted a limited injunction by the U.S. District Court for the Eastern District of Pennsylvania. The district court agreed with the DOL’s allegations that harm was being done, by the Pennsylvania-based fiduciaries of welfare benefit plans sponsored by employers nationwide, to the plans’ participants.
Defendants John J. Koresko, V, PennMont Benefit Services, Inc., Penn Public Trust, Koresko and Associates, P.C., and Koresko Law Firm, P.C., their agents, employees, service providers, accountants, attorneys, and any other party acting at their direction, were removed from positions held with the Single Employer Welfare Benefit Plan Trust (SEWBPT) and/or the Regional Employers Assurance League Voluntary Employees’ Beneficiary Association Trust (REAL VEBA). The defendants were also enjoined from serving as administrator, fiduciary, officer, trustee, custodian, counsel, agent, representative (including acting as attorney in fact), or consultant or adviser of the plans or employer arrangements participating in the SEWBPT and/or the REAL VEBA.
An independent fiduciary for the plans was also appointed by the court to obtain an inventory of assets and to distribute the assets of the plans appropriately.
Defendants John J. Koresko, V, PennMont Benefit Services, Inc., Penn Public Trust, Koresko and Associates, P.C., and Koresko Law Firm, P.C., their agents, employees, service providers, accountants, attorneys, and any other party acting at their direction, were removed from positions held with the Single Employer Welfare Benefit Plan Trust (SEWBPT) and/or the Regional Employers Assurance League Voluntary Employees’ Beneficiary Association Trust (REAL VEBA). The defendants were also enjoined from serving as administrator, fiduciary, officer, trustee, custodian, counsel, agent, representative (including acting as attorney in fact), or consultant or adviser of the plans or employer arrangements participating in the SEWBPT and/or the REAL VEBA.
An independent fiduciary for the plans was also appointed by the court to obtain an inventory of assets and to distribute the assets of the plans appropriately.
Kenneth Elliot KAE Insurance Co: Sea Nine VEBA Important
Kenneth Elliot KAE Insurance Co: Sea Nine VEBA Important: As of August 23,2013, the IRS has closed audits of 12 Sea Nine VEBA plan-participating taxpayers who were referred to Sea Nine by Sarva. For...
Protecting Clients from Fraud, Incompetence, and Scam
This is a story about Bruce Hink and how the IRS fined him $200,000 a year for being in what they called a “listed transaction." Excerpts have been taken from this book about: Bruce Hink, who has given me permission to utilize his name and circumstances, is a perfect example of what the IRS is doing to unsuspecting business owners. What follows is a story about Bruce Hink and how the IRS fined him $200,000 a year for being in what they called a “listed transaction."
Published by John Wiley and Sons, Inc. - Copyright 2010. All rights reserved.
In addition, I believe that the accountant who signed the tax return and the insurance agent who sold the retirement plan will each be fined $200,000 as material advisers. We have received a large number of calls for help from accountants, business owners, and insurance agents in similar situations. Don’t think this will happen to you. It is happening to a lot of accountants and business owners, because most of these so-called listed, abusive plans, or plans substantially similar to the so-called listed, are currently being sold by most insurance agents.
Bruce was a small business owner facing $400,000 in IRS penalties for 2004 and 2005 for his 412(i) plan (IRC6707A). Here is how the story developed.
In 2002 an insurance agent representing a 100-year-old well-established insurance company suggested he start a pension plan. Bruce was given a portfolio of information from the insurance company, which was given to the company’s outside CPA to review and to offer an opinion. The CPA gave the plan the green light and the plan was started for tax year 2002.
Contributions were made in 2003. Then the administrator came out with amendments to the plan, based on new IRS guidelines, in October 2004.
The business owner’s agent disappeared in May 2005 before implementing the new guidelines from the administrator with the insurance company. The business owner was left with a refund check from the insurance company, a deduction claim on his 2004 tax return that had not been applied, and without an agent.
I took six months of making calls to the insurance company to get a new insurance agent assigned. By then, the IRS had started an examination of the pension plan. Bruce asked for advice from the CPA and the local attorney (who had no previous experience in such cases), which made matters worse, with a “big name” law firm being recommended and more than $30,000 in additional legal fees being billed in three months.
To make a long story short, the audit stretched on for more than two years to examine a two-year old pension with four participants and $178,000 in contributions.
During the audit, no funds went to the insurance company. The company was awaiting IRS approval and restructuring the plan as a traditional defined benefit plan, which the administrator had suggested and which the IRS had indicated would be acceptable. The $90,000 2005 contribution was put into the company’s retirement bank account along with the 2004 contribution.
In March 2008, the business owner received an apology from the IRS agent who headed the examination. Even this sympathetic IRS agent thinks there is a problem with the IRS enforcement of these Draconian penalties. Below is one of her emails to the business owner who was fined $400,000.
From: XXXXXXXX XXXXX
Date: Tue, Mar 4, 2008 at 7:12 AM
Subject: RE: Urgent
To: Bruce Hink
Thanks Bruce – yes – please just overnight then to the Grand Rapids address. Once again, I’m sorry about this. Basically, our Counsel told us that we needed language specific to the IRC 6707A penalty in order for that statute to be extended. I will ask the Reviewer to hold off an extra day.
I’m also very sorry that this is getting you down. Deeply sorry. It’s very difficult for me as well – before I started working on this project (412(i)) I was doing audits of 401(k) and profit sharing plans. If there was an error on the plan, the employer would just fix it and the audit was over. There wasn’t anything controversial about it – and I felt like I was helping people – employers and plan participants. I really liked my job. In two years time, that has completely changed. I know it’s not very “professional” to make such confessions – so forgive me. But I guess I just wanted you to know that I really sympathize with your situation – and have been doing whatever I can to help. I know that having this hanging over your head can’t be fun – but as this project goes forward – I think that the IRS is going to have to soften their position somewhat – so these delays may be to your benefit.
Also, I’m not really supposed to be sending emails to you – but when I went through the file I couldn’t find a good phone number for you. Could you just send me a note or an email with a current phone number?
Looking to receive the signed 872s on Thursday. If you have any questions at any time – please call me at XXX-XXX-XXXX. I’m usually in the office in the mornings.
The IRS subsequently denied any appeal and ruled in October 2008 that the $400,000 penalty would stand. Could You or One of Your Clients Be Next?
In addition, I believe that the accountant who signed the tax return and the insurance agent who sold the retirement plan will each be fined $200,000 as material advisers. We have received a large number of calls for help from accountants, business owners, and insurance agents in similar situations. Don’t think this will happen to you. It is happening to a lot of accountants and business owners, because most of these so-called listed, abusive plans, or plans substantially similar to the so-called listed, are currently being sold by most insurance agents.
Bruce was a small business owner facing $400,000 in IRS penalties for 2004 and 2005 for his 412(i) plan (IRC6707A). Here is how the story developed.
In 2002 an insurance agent representing a 100-year-old well-established insurance company suggested he start a pension plan. Bruce was given a portfolio of information from the insurance company, which was given to the company’s outside CPA to review and to offer an opinion. The CPA gave the plan the green light and the plan was started for tax year 2002.
Contributions were made in 2003. Then the administrator came out with amendments to the plan, based on new IRS guidelines, in October 2004.
The business owner’s agent disappeared in May 2005 before implementing the new guidelines from the administrator with the insurance company. The business owner was left with a refund check from the insurance company, a deduction claim on his 2004 tax return that had not been applied, and without an agent.
I took six months of making calls to the insurance company to get a new insurance agent assigned. By then, the IRS had started an examination of the pension plan. Bruce asked for advice from the CPA and the local attorney (who had no previous experience in such cases), which made matters worse, with a “big name” law firm being recommended and more than $30,000 in additional legal fees being billed in three months.
To make a long story short, the audit stretched on for more than two years to examine a two-year old pension with four participants and $178,000 in contributions.
During the audit, no funds went to the insurance company. The company was awaiting IRS approval and restructuring the plan as a traditional defined benefit plan, which the administrator had suggested and which the IRS had indicated would be acceptable. The $90,000 2005 contribution was put into the company’s retirement bank account along with the 2004 contribution.
In March 2008, the business owner received an apology from the IRS agent who headed the examination. Even this sympathetic IRS agent thinks there is a problem with the IRS enforcement of these Draconian penalties. Below is one of her emails to the business owner who was fined $400,000.
From: XXXXXXXX XXXXX
Date: Tue, Mar 4, 2008 at 7:12 AM
Subject: RE: Urgent
To: Bruce Hink
Thanks Bruce – yes – please just overnight then to the Grand Rapids address. Once again, I’m sorry about this. Basically, our Counsel told us that we needed language specific to the IRC 6707A penalty in order for that statute to be extended. I will ask the Reviewer to hold off an extra day.
I’m also very sorry that this is getting you down. Deeply sorry. It’s very difficult for me as well – before I started working on this project (412(i)) I was doing audits of 401(k) and profit sharing plans. If there was an error on the plan, the employer would just fix it and the audit was over. There wasn’t anything controversial about it – and I felt like I was helping people – employers and plan participants. I really liked my job. In two years time, that has completely changed. I know it’s not very “professional” to make such confessions – so forgive me. But I guess I just wanted you to know that I really sympathize with your situation – and have been doing whatever I can to help. I know that having this hanging over your head can’t be fun – but as this project goes forward – I think that the IRS is going to have to soften their position somewhat – so these delays may be to your benefit.
Also, I’m not really supposed to be sending emails to you – but when I went through the file I couldn’t find a good phone number for you. Could you just send me a note or an email with a current phone number?
Looking to receive the signed 872s on Thursday. If you have any questions at any time – please call me at XXX-XXX-XXXX. I’m usually in the office in the mornings.
The IRS subsequently denied any appeal and ruled in October 2008 that the $400,000 penalty would stand. Could You or One of Your Clients Be Next?
As an expert witness Lance Wallach's side has never lost a case. People need to be careful of 419 Welfare Benefit Plans, 412i plans, Section 79 plans and Captive Insurance Plans. Most of these plans are sold by insurance agents. If you are in an abusive, listed or similar transaction plan you need to file under IRS 6707a. The participant files form 8886, and the salesmen or accountant who signs the tax returns files form 8918 if they got paid over $10,000. They are called Material Advisors and face a minimum $100,000 fine. Some plans are offshore which could involve FBAR or OVDI filings. If you have money overseas you probably need to file for IRS tax amnesty. If you want to reduce the tax we suggest that you first file and then opt out. For more information Google Lance Wallach.
The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.
Certain Types of Arrangements That do not Satisfy the Requirements of Internal Revenue Code Section 419A(f)(6)
In Notice 95-34, 1995-1 C.B. 309, the IRS identified . Those arrangements typically
require large employer contributions relative to the cost of the coverage for
the benefits to be provided under the plan. The plans identified in the notice
often maintain separate accounting of the assets attributable to the
contributions made by each participating employer. See Booth v. Commissioner, 108 T.C. 524
(1997), for an arrangement using a separate accounting system that does not
qualify under the 10-or-more employer plan exception. In some cases, an employer’s contributions
are related to the claims experience of its employees, while in other cases
benefits are reduced if assets derived from an employer’s contributions are
insufficient to fund the benefits to that employer’s employees. Thus, a
particular employer’s contributions or its employees’ benefits may be determined
in a way that insulates the employer to a significant extent from the experience
of other participating employers.
The arrangements described in Notice 95-34 and
similar arrangements do not satisfy the requirements of Section 419A(f)(6) of the Code and do not provide the tax
deductions claimed by their promoters for any of several reasons. For example,
such an arrangement may be providing deferred compensation; the arrangement may
be separate plans maintained for each employer; or the plan may be maintaining,
in form or in operation, experience rating arrangements with respect to individual
employers (e.g., where the employers have reason to expect that, at least for
the most part, their contributions will benefit only their own employees). The
notice also states that even if an arrangement satisfies the requirements of
Section 419A(f)(6), so that the deduction limits of Sections 419 and 419A do not
apply to the arrangement, the employer contributions may represent expenses that
are not deductible under other sections of the Code.
Could You or One of Your Clients Be Next?
Protecting Clients From Fraud Incompetence and Scams
Published by John Wiley &
Sons
Chapter 1
Lance Wallach
Some of the
areas SB/SE will be examining include pass-through entities, high-income
filers, and abusive transactions. S corporations are likely to receive
particular scrutiny. Further review would not be limited to S corporations, but
would extend to pass-through entities like partnerships, which can expect to
receive a “significant amount of attention” because SB/SE has found an area of
abuse and would like to curb what is called a growing trend of abusive
transactions. There also will be a renewed effort to address high-income
filers, typically classified as those with an adjusted gross income of more
than $200,000.
The IRS has been cracking down on what it
considers to be abusive tax shelters. Many of them are being marketed to small
business owners by insurance professionals, financial planners, and even accountants
and attorneys. I speak at numerous conventions, for both business owners and
accountants. And after I speak, I am always approached by many people who have
questions about tax reduction plans that they have heard about.
I have been
an expert witness in many of these 419 and 412(i) lawsuits and I have not lost
one of them. If you sold one or more of these plans, get someone who really
knows what they are doing to help you immediately. Many advisors will take your
money and claim to be able to help you. Make sure they have experience helping
agents that have sold these types of plans. Make sure they have experience
helping accountants who signed the tax returns. IRS calls them material
advisors and fines them $200,000 if they are incorporated or $100,000 if not.
Do not let them learn on the job, with your career and money at stake.
Fear will
not adjust your opponent’s motive. Strategic action on your part, though, will
make your business adept enough to handle adversarial challenges. You need
advocates with tax law knowledge who can strategically allocate your business
assets, utilizing legal methods synchronized to an understanding of the most
recently updated IRS code provisions. You should meet the IRS challenge as an
opportunity to advance your business and wealth-growth goals.
Let us
discuss an integrated team approach to protecting your assets, a strategy that
should be in place long before the IRS, or other vampirical entities seeking to
drain your assets appear at the doorstep. Nothing you do as a business owner is
as important as understanding how to minimize your risk.
Summary
Macroeconomic
conditions have resulted in stupefying losses to the investment portfolios of
both the public and private sectors. The country is rife with projected pension
fund insolvencies totaling literally hundreds of billions of dollars. Our
(read: taxpayers) share is staggering. The government is looking for revenue
wherever it can find it. Cue the Internal Revenue Service!
LanceWallach, National Society of Accountants Speaker of the Year and member of the
American Institute of CPAs faculty of teaching professionals, is a frequent
speaker on retirement plans, financial and estate planning, and abusive tax
shelters. He speaks at more than ten
conventions annually and writes for over fifty publications. 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. Mr. Wallach may be reached at
516/938.5007, wallachinc@gmail.com, or at www.taxaudit419.com or
www.lancewallach.com.
The information provided herein is not intended as legal,
accounting, financial or any type of advice for any specific individual or
other entity. You should contact an appropriate professional for any such
advice.
IRS Says Most 419 Plans Are Abusive Tax Shelters
On October 17, 2007, the IRS, in Notice 2007-83, identified as listed transactions certain trust
arrangements involving cash value life insurance policies. Revenue Ruling 2007-65, issued simultaneously,
addressed situations wherein the tax deduction has been disallowed, in whole or in part, for premiums paid on such cash value life insurance policies. These arrangements claim to be welfare benefit plans.
Read more here:
IRS Says Most 419 Plans Are Abusive Tax Shelters
As an expert witness Lance Wallach side has never lost a case: Lance Wallach
As an expert witness Lance Wallach side has never lost a case: Lance Wallach: Lance Wallach An organization to help those harmed by the IRS, don't let what happened to Bruce happen to you
Section 79 Plans: Section 79, Captive Insurance, IRS Audits and Lawsuits on 419 and 412i Plans
Hg Experts Legal Experts Directory
While every effort has been made to ensure the accuracy of this publication, it is not intended to provide legal advice as individual situations will differ and should be discussed with an expert and/or lawyer. For specific technical or legal advice on the information provided and related topics, please contact the author.
By Lance Wallach, CLU, CHFC
Abusive Tax Shelter, Listed Transaction, Reportable Transaction Expert Witness
IRS Attacks Business Owners in 419, 412, Section 79 and Captive Insurance Plans Under Section 6707A - By Lance Wallach - Taxpayers who previously adopted 419, 412i, captive insurance or Section 79 plans are in big trouble. In recent years, the IRS has identified many of these arrangements as abusive devices to funnel tax deductible dollars to shareholders and classified these arrangements as listed transactions."
These plans were sold by insurance agents, financial planners, accountants and attorneys seeking large life insurance commissions. In general, taxpayers who engage in a “listed transaction” must report such transaction to the IRS on Form 8886 every year that they “participate” in the transaction, and you do not necessarily have to make a contribution or claim a tax deduction to participate. Section 6707A of the Code imposes severe penalties for failure to file Form 8886 with respect to a listed transaction. But you are also in trouble if you file incorrectly. I have received numerous phone calls from business owners who filed and still got fined. Not only do you have to file Form 8886, but it also has to be prepared correctly. I only know of two people in the U.S. who have filed these forms properly for clients. They tell me that was after hundreds of hours of research and over 50 phones calls to various IRS personnel. The filing instructions for Form 8886 presume a timely filling. Most people file late and follow the directions for currently preparing the forms. Then the IRS fines the business owner. The tax court does not have jurisdiction to abate or lower such penalties imposed by the IRS.
"Many taxpayers who are no longer taking current tax deductions for these plans continue to enjoy the benefit of previous tax deductions by continuing the deferral of income from contributions and deductions taken in prior years."
Many business owners adopted 412i, 419, captive insurance and Section 79 plans based upon representations provided by insurance professionals that the plans were legitimate plans and were not informed that they were engaging in a listed transaction. Upon audit, these taxpayers were shocked when the IRS asserted penalties under Section 6707A of the Code in the hundreds of thousands of dollars. Numerous complaints from these taxpayers caused Congress to impose a moratorium on assessment of Section 6707A penalties.
The moratorium on IRS fines expired on June 1, 2010. The IRS immediately started sending out notices proposing the imposition of Section 6707A penalties along with requests for lengthy extensions of the Statute of Limitations for the purpose of assessing tax. Many of these taxpayers stopped taking deductions for contributions to these plans years ago, and are confused and upset by the IRS’s inquiry, especially when the taxpayer had previously reached a monetary settlement with the IRS regarding its deductions. Logic and common sense dictate that a penalty should not apply if the taxpayer no longer benefits from the arrangement. Treas. Reg. Sec. 1.6011-4(c)(3)(i) provides that a taxpayer has participated in a listed transaction if the taxpayer’s tax return reflects tax consequences or a tax strategy described in the published guidance identifying the transaction as a listed transaction or a transaction that is the same or substantially similar to a listed transaction.
Clearly, the primary benefit in the participation of these plans is the large tax deduction generated by such participation. Many taxpayers who are no longer taking current tax deductions for these plans continue to enjoy the benefit of previous tax deductions by continuing the deferral of income from contributions and deductions taken in prior years. While the regulations do not expand on what constitutes “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. Another important issue is that the IRS has called CPAs material advisors if they signed tax returns containing the plan, and got paid a certain amount of money for tax advice on the plan. The fine is $100,000 for the CPA, or $200,000 if the CPA is incorporated. To avoid the fine, the CPA has to properly file Form 8918.
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, abusive tax shelters, financial, international tax, and estate planning. He writes about 412(i), 419, Section79, FBAR and captive insurance plans. He speaks at more than ten conventions annually, writes for more than 50 publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Public 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 the 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.taxadvisorexpert.com.
"Many taxpayers who are no longer taking current tax deductions for these plans continue to enjoy the benefit of previous tax deductions by continuing the deferral of income from contributions and deductions taken in prior years."
Many business owners adopted 412i, 419, captive insurance and Section 79 plans based upon representations provided by insurance professionals that the plans were legitimate plans and were not informed that they were engaging in a listed transaction. Upon audit, these taxpayers were shocked when the IRS asserted penalties under Section 6707A of the Code in the hundreds of thousands of dollars. Numerous complaints from these taxpayers caused Congress to impose a moratorium on assessment of Section 6707A penalties.
The moratorium on IRS fines expired on June 1, 2010. The IRS immediately started sending out notices proposing the imposition of Section 6707A penalties along with requests for lengthy extensions of the Statute of Limitations for the purpose of assessing tax. Many of these taxpayers stopped taking deductions for contributions to these plans years ago, and are confused and upset by the IRS’s inquiry, especially when the taxpayer had previously reached a monetary settlement with the IRS regarding its deductions. Logic and common sense dictate that a penalty should not apply if the taxpayer no longer benefits from the arrangement. Treas. Reg. Sec. 1.6011-4(c)(3)(i) provides that a taxpayer has participated in a listed transaction if the taxpayer’s tax return reflects tax consequences or a tax strategy described in the published guidance identifying the transaction as a listed transaction or a transaction that is the same or substantially similar to a listed transaction.
Clearly, the primary benefit in the participation of these plans is the large tax deduction generated by such participation. Many taxpayers who are no longer taking current tax deductions for these plans continue to enjoy the benefit of previous tax deductions by continuing the deferral of income from contributions and deductions taken in prior years. While the regulations do not expand on what constitutes “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. Another important issue is that the IRS has called CPAs material advisors if they signed tax returns containing the plan, and got paid a certain amount of money for tax advice on the plan. The fine is $100,000 for the CPA, or $200,000 if the CPA is incorporated. To avoid the fine, the CPA has to properly file Form 8918.
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, abusive tax shelters, financial, international tax, and estate planning. He writes about 412(i), 419, Section79, FBAR and captive insurance plans. He speaks at more than ten conventions annually, writes for more than 50 publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Public 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 the 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.taxadvisorexpert.com.
The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.
While every effort has been made to ensure the accuracy of this publication, it is not intended to provide legal advice as individual situations will differ and should be discussed with an expert and/or lawyer. For specific technical or legal advice on the information provided and related topics, please contact the author.
Help with Common IRS Problems: Reportable Transactions & 419 Plans Litigation: La...
Help with Common IRS Problems: Reportable Transactions & 419 Plans Litigation: La...: Reportable Transactions & 419 Plans Litigation: Labels: Lance Wallach , lance wallach expert witness , tax , Taxaudits 3 comme...
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FINANCE
Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots, by Sid Kess
Best Sellers – March 2008
Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots, by Sid Kess
Author/Moderator: Lance Wallach, CLU, CHFC, CIMC
Publisher: AICPA
This course will enable the practitioner to better understand many of the abusive insurance and annuity-based products being marketed to your clients and how you can alleviate exposure to IRS scrutiny.
Objectives:
· Identify potentially abusive deductions claimed on your client’s tax return
· Enable the practitioner to advise his clients so they can avoid IRS penalties and deduction disallowances
· Learn the pros and cons of the current strategies being employed by financial professionals in developing comprehensive financial plans for individuals and businesses
· Learn to avoid financial exposure to yourself and your clients for aggressive insurance, retirement and financial planning strategies being marketed today
Prerequisite: None
Accepted for CFP® credit.
Text Product# 733720
Availability:In Stock
Regular:$150.00
AICPA Member:$120.00
Contact Lance Wallach to purchase: 516.938.5007, wallachinc@gmail.com
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
Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots, by Sid Kess
Author/Moderator: Lance Wallach, CLU, CHFC, CIMC
Publisher: AICPA
This course will enable the practitioner to better understand many of the abusive insurance and annuity-based products being marketed to your clients and how you can alleviate exposure to IRS scrutiny.
Objectives:
· Identify potentially abusive deductions claimed on your client’s tax return
· Enable the practitioner to advise his clients so they can avoid IRS penalties and deduction disallowances
· Learn the pros and cons of the current strategies being employed by financial professionals in developing comprehensive financial plans for individuals and businesses
· Learn to avoid financial exposure to yourself and your clients for aggressive insurance, retirement and financial planning strategies being marketed today
Prerequisite: None
Accepted for CFP® credit.
Text Product# 733720
Availability:In Stock
Regular:$150.00
AICPA Member:$120.00
Contact Lance Wallach to purchase: 516.938.5007, wallachinc@gmail.com
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
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419, 412i, IRS audits, Lance Wallach, Google him helps, The following had something to do with this.
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
r Anthony Fakouri
Steve Burgess
Robin Weingast
IRS audits 419 412i captive insurance and section 79 plans. Lance Wallach will help you.
IRS audits section 79 419 412i plans. www.lancewallach.com for help
, IRS raids, Niche, Robin Weingast, Lance Wallach helps, Sadi trust, grist Mill trust, nova 419 welfare benefit plan problems and how Lance Wallach helps.www.vebaplan.com for more help. Sea Nine VEBA, 419, 412i, IRS audits,Sea Nine VEBA, are all audited by the IRS and people in them probably need help.
Sea Nine VEBA, 419,412i are all IRS audit targets. Lance Wallach can help, www.tazaudit419.com
419, 412i, IRS audits, Lance Wallach, Google him helps, The following had something to do with this. Author to write about these problems.
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
Anthony Fakouri
Steve Burgess
Robin Weingast
" Lance Wallach will help fix the problems that people have that are or were in the plans.
"Professional Benefits Trust" PBI
"Sea Nine Veba"
Bisys
The "Beta Plan"
The "Millennium Plan"
Niche
The "Ridge Plan"
The "Compass Welfare Benefit Plan"
"Section 79 Plans"
"Captive Insurance"
and other similar "412i retirement plans" and "419 welfare benefit plans
Lance Wallach, www.taxaudit419.com will help you with these problems and more like section 79, captive insurance lawsuits and IRS audits. People in the section 79 plans 419 welfare benefit plans captive insurance and 412i pension plans are getting audited by the IRS and then they sue. Google Lance Wallach for help with this. If you need help Lance Wallach as an expert witness has never lost a case. You need help NOW. Google lance wallach or www.vebaplan.com for 419 412i captive insurance or section 79 audits lawsuits get your money back etc.
Customers of James Cunningham d/b/a Cunningham Financial or CFG Consulting LLC? We want to speak with you!
IRS audits and lawsuits result from 419 412i captive insurance and section 79 plans. As an expert witness Lance Wallach has never lost a case.