Lance Wallach | Remodeling

Lance Wallach | Remodeling

HAVE YOU BEEN THE VICTIM OF THE SALE OF ABUSIVE LIFE INSURANCE AND ANNUITY PRODUCTS SOLD AS PART OF A PENSION PLAN OR RETIREMENT PLAN?

Abusive Tax Shelters, Insurance and Annuity Product Fraud Lawsuit

RECOVER YOUR LOSSES FROM LIFE INSURANCE 412 (i) AND ANNUITY PRODUCTS SOLD AS PART OF A PENSION PLAN OR RETIREMENT PLAN

Insurance and Annuity Product Fraud Lawsuit

Life Insurance Companies and their Agents have been selling abusive life insurance and annuity products.  Many pension plans have been promoted as legitimate retirement plans which contain various life insurance products and annuities.  Unfortunately the Internal Revenue Service (“IRS”) has now attacked many of these pension and retirement plans and is conducting audits to demand payment for taxes, penalties and interest and attempting to disqualify many plans.

If you are an accountant, business owner, corporate officer, dentist, doctor, professional athlete, professional or corporation of high net worth, you were unscrupulously targeted by life insurance companies and their agents to purchase a 412i defined benefit pension plan. You were chosen to purchase a 412i plan because you have the net worth to pay for it.

Our investigation has disclosed that many life insurance companies, promoters, attorneys,

and accountants promoted and sold these plans, including but not limited to the following:

•  American General Life Insurance Company
•  Guardian Life Insurance Company
•  Hartford Life and Annuity Insurance Company
•  Indianapolis Life Insurance Company
•  Pacific Life Insurance Company
•  Pension Services, LLC
•  Many Other Life Insurance Companies and Agents

The individuals and groups above devised a scheme to sell abusive tax shelters under the auspices of Section 412(i) of the tax code. A 412(i) is a defined benefit pension plan. It provides specific retirement benefits to participants once they reach retirement and must contain assets sufficient to pay those benefits. A 412(i) plan differs from other defined benefit pension plans in that it must be funded exclusively by the purchase of individual life insurance products. To create a 412(i) plan, there must

be a trust to hold the assets. The employer funds the plan by making cash contributions to the trust, and the Code allows the employer to take a tax deduction in the amount of the contributions, i.e. the entire amount.

The trust uses the contributed funds to purchase some combination of life insurance products (insurance or annuities) for the plan. As the plan participants retire, the trust will usually sell the policies for their present cash value and purchase annuities with the proceeds. The revenue stream from the annuities pays the specified retirement benefit to plan participants.

These defendants (with the aid and knowledge of the insurance companies) used the traditional structure and sold life insurance policies with excessively high premiums. The trust then uses the large cash contributions to pay high insurance premiums and the employer takes a deduction for the sum of those large contributions. As you might expect, these policies were designed with excessively high fees or “loads” which provided exorbitant commissions to the insurance companies and the agents who sold the products.

The policies that were sold were termed Springing Cash Value Policies. They had little or no cash value for the first 5-7 years, after which they had significant cash value. Under this scheme, after 5-7 years, and just before the cash value sprung, the participant typically purchases the policy from the trust for the policy’s surrender value. In theory, you have a tax free transaction.

The IRS does not recognize the tax benefit of such a plan and has repeatedly issued announcements indicating that such plans are contrary to federal tax laws and regulations.

Have you received a letter from the IRS either (1) informing you of an upcoming audit of your plan or (2) demanding payment for substantial tax “penalties and interest”? The “tax free” benefit pension plan you purchased might be a scam, a fraud.  Please allow us to speak with you and review your documentation to help you to determine your best course of action.  Your communications will be treated with the strictest attorney-client confidence.

If you were a victim of such a sale of a 412i or 419 plan, we encourage you to contact us immediately .  You may also receive a free initial consultation by telephone at 516 9357346  If you desire a free initial phone consultation please leave a specific time or time period within which to contact you.

Since you have already expanded a substantial amount of money in your pension plan and believed it was a legitimate retirement plan, you are obviously shocked to now learn that major life insurance companies and their agents may have sold you improper retirement plans simply to generate enormous commissions on life insurance and annuities. www.taxaudit419 and www.vebaplan.com have more information.

We also help with abusive tax shelters like 419 welfare benefit plans. In 2002 Lance Wallach wrote to Hartford and other insurance companies telling them that IRS will be increasing 419 audits and law firms would be suing them. What did Hartford do? They sent out some emails to others including their compliance department and continued to sell 419 plans. Give us a call if you want a copy of this.

Expert help with 419a, 419e, 419, 412i, welfare benefit plans, 6707a penalties, form 8886, IRS audits, Section 79, Captive insurance, FBAR, tax masters, jk harris, wpi, us tax shield

Expert help with 419a, 419e, 419, 412i, welfare benefit plans, 6707a penalties, form 8886, IRS audits, Section 79, Captive insurance, FBAR, tax masters, jk harris, wpi, us tax shield

Don't face an audit alone! You can avoid 6707A penalties if you are facing an IRS 419 plan or 412i plan audit. Call these experts today for a free phone consultation.

Don't face an audit alone! You can avoid 6707A penalties if you are facing an IRS 419 plan or 412i plan audit. Call these experts today for a free phone consultation.

http://taxadvisorexperts.com/

419 Plans Litigation: Don't Become A Material Advisor

419 Plans Litigation: Don't Become A Material Advisor

Contact Lance Wallach for help with 419e, 412i, captive insurance, Section 79

Contact Lance Wallach for help with 419e,412i,captive insurance,Section 79

419 Plan, 412i Plan, Welfare benefit plan assistance, audits & Abusive tax shelters

419 Plan, 412i Plan, Welfare benefit plan assistance, audits & Abusive tax shelters

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 lawsuits

Lance Wallach - Expert Witness Testimony

Lance Wallach - Expert Witness Testimony

Material Advisors & 419 Plans Litigation: Lance Wallach National Society of Accountants Spea...

Material Advisors & 419 Plans Litigation: Lance Wallach National Society of Accountants Spea...

All You Need To know_Lance Wallach_#abusivetaxshelters #419plans …

All You Need To know_Lance Wallach_#abusivetaxshelters #419plans  …

Some 419 Insurance Welfare Benefit Plans Continue To Get Accountants Into Trouble

by Lance Wallach

Popular so-called “419 Insurance Welfare Benefit Plans”, sold by most insurance professionals, are getting accountants and their clients into more and more trouble. A CPA who is approached by a client about one of the abusive arrangements and/or situations to be described and discussed in this article must exercise the utmost degree of caution, not only on behalf of the client, but for his/her own good as well. The penalties noted in this article can also be applied to practitioners who prepare and/or sign returns that fail to properly disclose listed transactions, including those discussed herein. 

On October 17, 2007, the IRS issued Notice 2007-83, Notice 2007-84, and Revenue Ruling 2007-65. Notice 2007-83 essentially lists the characteristics of welfare benefit plans that the Service regards as listed transactions. Put simply, to be a listed transaction, a plan cannot rely on the union exception set forth in IRC Section 419A(f)(5),there must be cash value life insurance within the plan and excessive tax deductions for life insurance, in excess of what may be permitted by Sections 419 and 419A, must have been claimed. 
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419, 412i, captive insurance and section 79 problems

200K Report Update- Lance Wallach 419, 412i, Sect 79, Captive Insurance

Section 79, Captive Insurance, IRS Audits and Lawsuits on 419 and 412i Plans - HGExperts.com

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.

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Lance Wallach,419 problems

Lance Wallach,419 problems

419 Plan, 419 Problems

419 Plan,419 Problems

Lance Wallach : 419 Litigation

Lance Wallach : About

IRS Attacks Business Owners in 419, 412, Section 79 and Captive Insurance Plans Under Section 6707A

by Lance Wallach

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."

continue reading the article

Small Business Retirement Plans Fuel Litigation: How to get fined $100,000 by the IRS and lose your...

Small Business Retirement Plans Fuel Litigation: How to get fined $100,000 by the IRS and lose your...: How to get fined $100,000 by the IRS and lose your license | BenefitsPro

419e 412i, tax shelters, IRS penalties, audits

Thursday, February 27, 2014

Section 79 by Lance Wallach, expert witness.

For businesses with 10 or fewer employees, the law prohibits full medical underwriting of the policies that are issued ("group" underwriting is required, which is much more risky for an insurance company).

Beginning this article, I wanted to reiterate my comments on implementing plans with fewer than 10 employees.

Amazingly, one of the insurance companies offering this plan seemly doesn't have the ability to issue non-medical underwriting policies. This is laughable and pathetic all at the same time, and a plan you'll want to stay far away from.

As I briefly alluded to in my previous article, one of the reasons I really do not like Section 79 plans is that they basically force employers and those helping them set up Section 79 plans to lie to the employees when implementing the plan.