As an expert witness Lance Wallach side has never lost a case: Sometimes the IRS might disagree with planning you...

As an expert witness Lance Wallach side has never lost a case: Sometimes the IRS might disagree with planning you...: Sometimes the IRS might disagree with planning you did with other advisors and you need to find help to ensure that your rights are protec...





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  • Tax Expert Lance Wallach Speaking at Attorney CPA ...

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    Tax Expert, Author, Expert Witness, Speaker Lance Wallachdiscussing tax audits, penalties, abusive tax ...



  • Captive Insurance & 419 Plans Litigation

    lancewallachchfc.blogspot.com/

  • 43 comments:

    1. 412i 419 sect 79 lawsuits audits www.lancewallach.com for help
      atlanta.craigslist.org › ... › atlanta › all gigs › event gigs‎
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      7 days ago - Lance Wallach helps with 419 problems. 412i 419 abusive tax shelters IRS audits, lawsuits, Lance Wallach will help www.vebaplan.com
      Tax Expert Lance Wallach Speaking at Attorney CPA Convention ...
      ► 7:55► 7:55
      www.dailymotion.com/.../xcfivs_tax-ex...‎
      Dailymotion
      Mar 2, 2010
      Tax Expert, Author, Expert Witness, Speaker Lance Wallach discussing tax audits, penalties, abusive tax ...
      Lance Wallach - www.taxaudit419.com - YouTube
      ► 0:55► 0:55
      www.youtube.com/watch?v...‎
      YouTube
      May 18, 2012 - Uploaded by Lance Wallach
      http://www.taxaudit419.com If you were in a 419 welfare benefit plan, a 412i type of plan, a retirement plan with ...
      More by Lance Wallach - in 57 Google+ circles
      Lance Wallach - www.taxaudit419.com - YouTube
      ► 1:05► 1:05
      www.youtube.com/watch?v=uHeIIpOUl4I‎
      YouTube
      May 18, 2012 - Uploaded by Lance Wallach
      http://www.taxaudit419.com If you were hurt by an insurance company/insurance agent selling you some type ...
      More by Lance Wallach - in 57 Google+ circles

      ReplyDelete
    2. ed Line Life, Security Mutual Life, West Coast Life
      Had tax problems Lance Wallach fixed
      From: New York City, New York - It was

      www.vebaplan.com for help

      ReplyDelete

      Lance WallachJanuary 24, 2014 at 9:40 AM
      Listed Transactions & 419 Plans Litigation
      412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.Benistar,412i Lawsuits,419 lawsuits,412i Help,419 Help, IRS Audits,412i Problems,412i problems, Expert Witness Lance Wallach,412i Help,419 Help, Benistar Lawsuits, 412i lawsuits,419 lawsuits,

      Wednesday, August 22, 2012

      Have You Dealt With Any Of These People?

      Kenny Hartstein Dennis Cunning Steve Toth
      Larry Bell Scott Ridge Randall Smith
      Greg Roper Tracy Sunderlage Joseph Donnelly
      Norm Bevan Michael Sonnenberg Judy Carsrud
      Dan Carpenter Michael Carroll Anthony Fakouri
      Steve Burgess Tom Crosswhite

      ReplyDelete
      Replies
      1. 200K Report Update-

        419, 412i, Sect 79, Captive Insuranceof an individual case would depend on the disclosures made and what the sellers knew or should have known about the risks.

        In 2004, the IRS issued notices and revenue rulings indicating that the plans were listed transactions. But plaintiffs' lawyers allege that there were earlier signs that the plans ran afoul of the tax laws, evidenced by the fact that the IRS is auditing plans that existed before 2004.

        "Insurance companies were aware this was dancing a tightrope," said William Noll, a tax attorney in Malvern, Pa. "These plans were being scrutinized by the IRS at the same time they were being promoted, but there wasn't any disclosure of the scrutiny to unwitting customers."

        A defense attorney, who represents benefits professionals in pending lawsuits, said the main defense is that the plans complied with the regulations at the time and that "nobody can predict the future."

        An employee benefits attorney who has settled several cases against insurance companies, said that although the lost tax benefit is not recoverable, other damages include the hefty commissions - which in one of his cases amounted to 400,000 the first year - as well as the costs of handling the audit and filing amended tax returns.
        Defying the individualized approach an attorney filed a class action in federal court against four insurance companies claiming that they were aware that since the 1980s the IRS had been calling the policies potentially abusive and that in 2002 the IRS gave lectures calling the plans not just abusive but "criminal." A judge dismissed the case against one of the insurers that sold 412(i) plans.
        The court said that the plaintiffs failed to show the statements made by the insurance companies were fraudulent at the time they were made, because

        Delete
      2. 200K Report Update-

        419, 412i, Sect 79, Captive Insuranceof an individual case would depend on the disclosures made and what the sellers knew or should have known about the risks.

        In 2004, the IRS issued notices and revenue rulings indicating that the plans were listed transactions. But plaintiffs' lawyers allege that there were earlier signs that the plans ran afoul of the tax laws, evidenced by the fact that the IRS is auditing plans that existed before 2004.

        "Insurance companies were aware this was dancing a tightrope," said William Noll, a tax attorney in Malvern, Pa. "These plans were being scrutinized by the IRS at the same time they were being promoted, but there wasn't any disclosure of the scrutiny to unwitting customers."

        A defense attorney, who represents benefits professionals in pending lawsuits, said the main defense is that the plans complied with the regulations at the time and that "nobody can predict the future."

        An employee benefits attorney who has settled several cases against insurance companies, said that although the lost tax benefit is not recoverable, other damages include the hefty commissions - which in one of his cases amounted to 400,000 the first year - as well as the costs of handling the audit and filing amended tax returns.
        Defying the individualized approach an attorney filed a class action in federal court against four insurance companies claiming that they were aware that since the 1980s the IRS had been calling the policies potentially abusive and that in 2002 the IRS gave lectures calling the plans not just abusive but "criminal." A judge dismissed the case against one of the insurers that sold 412(i) plans.
        The court said that the plaintiffs failed to show the statements made by the insurance companies were fraudulent at the time they were made, because

        Delete
    3. Lance Wallach Life Insurance

      Thursday, February 27, 2014
      Captive Insurance Buyer Beware
      Hg Experts
      Legal Experts Directory


      Captive Insurance Buyer Beware
      By Lance Wallach, CLU, CHFC Abusive Tax Shelter, Listed Transaction, Reportable Transaction Expert Witness

      Is a captive insurance cell the way to go? - Accounting Today - Captive Insurance: Achieve large tax and cost reductions by renting a “CAPTIVE”. Most accountants and small business owners are unfamiliar with a great way to reduce taxes and expenses. By either creating or sharing “a captive insurance company”, substantial tax and cost savings will benefit the small business owner.

      Over 80% of Fortune 500 companies take advantage of some kind of captive insurance company arrangement. They set up their own insurance companies to provide coverage when they think outside insurers are charging too much, or coverage is simply unavailable. The parent company creates a captive so that it has a self-financing option for buying insurance. The captive then either retains the risk of providing insurance or pays reinsurers (companies that reinsure insurers) to take the risk.

      If you buy insurance from a standard insurance company, your money buys a service, but the money is spent and gone forever. When you utilize or “rent a captive”, your money buys a service but it is invested with a good possibility of a return.

      In the event of a claim, the company pays claims from its captive or from its reinsurer. To keep costs down, captives are often based in places where there is favorable tax treatment and less onerous regulation (i.e. Vermont, South Carolina, and Bermuda).

      Optimum utilization of a captive by a small business, medical practice, or professional.

      The best way for a small business, medical practice, etc., to take advantage of captive benefits is to share or rent a large captive. You can significantly decrease your costs of insurance and obtain tax deductions at the same time. There are, as well, significant tax advantages to renting a large captive as opposed to owning a captive.

      ReplyDelete
    4. 412i-419 Plans
      419 & 412i benefit plan,abusive tax shelters, Lance Wallach Expert Witness

      Tuesday, March 25, 2014
      Section 79 Plans: WHAT IS A SECTION 79 PLAN?
      Section 79 Plans: WHAT IS A SECTION 79 PLAN?: Section 79 plans are commonly known for the $50,000 free term life insurance they can provide for employees. Less commonly known is tha...





      26 U.S. Code § 412 - Minimum funding standards


      Current through Pub. L. 113-86, except 113-79. (See Public Laws for the current Congress.)
      US Code
      Notes
      Updates
      PREV | NEXT
      (a) Requirement to meet minimum funding standard
      (1) In general
      A plan to which this section applies shall satisfy the minimum funding standard applicable to the plan for any plan year.
      (2) Minimum funding standard
      For purposes of paragraph (1), a plan shall be treated as satisfying the minimum funding standard for a plan year if—
      (A) in the case of a defined benefit plan which is not a multiemployer plan, the employer makes contributions to or under the plan for the plan year which, in the aggregate, are not less than the minimum required contribution determined under section 430 for the plan for the plan year,
      (B) in the case of a money purchase plan which is not a multiemployer plan, the employer makes contributions to or under the plan for the plan year which are required und

      ReplyDelete
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    5. CJA operates two off-shore reinsurance companies: RMC Property and Casualty Company and RMC Reinsurance Company Limited. Through these companies, CJA is able to offer unique insurance solutions to their clients.

      Services include accepting life and health reinsurance from United States domiciled legal reserve life insurance carriers with substantiated ratings, individual life and annuity contracts including private annuities, and solutions for captive insurance companies.

      ReplyDelete

    6. • Will the IRS impose interest and penalties?

      • What is a “listed transaction” ?

      • What is Form 8886, and what are the penalties for failing to file Form 8886?

      • Will I be responsible even if I relied on my tax advisor?

      • What recourse do I have against those that promoted and sold the Sea Nine VEBA?

      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

      ReplyDelete

      Lance WallachApril 29, 2014 at 9:00 AM
      Compass welfare benefit plan
      Sea Nine VEBA
      Professional Benefits Trust
      Integrity 419
      Integrity Benefit Plan
      Veba Plan
      Sterling 419

      People, law firms, etc., affiliated with plans:
      Doug Williams
      Arch Bonnema
      Steve Toth
      Michael Sonnenberg
      Ron Snyder
      Brian Cave
      Norman Bevan
      Dennis Cunning
      Williams Coulson
      Phil Rowe
      Kenny Hartstein
      Judy Carsrud
      Michael Lloyd
      Greenberg Tarig

      If you were involved with one of these plans there is a great chance that you need to file, or properly re-file your 8886 form to avoid
      fines and penalties.

      Call 516-935-7346 for assistance in the analysis of your needs today.

      ReplyDelete
      Replies
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    7. ATRINA KNIEST; GEORGE MCLAIN

      v.

      PENNMONT BENEFIT SERVICES, INC.; JOHN J. KORESKO, V;
      THE KORESKO LAW FIRM, P.C.;
      REGIONAL EMPLOYERS ASSURANCE LEAGUES VOLUNTARY
      EMPLOYEES BENEFICIARY ASSOCIATION TRUST;
      SINGLE EMPLOYER WELFARE BENEFIT PLAN TRUST;
      PENN PUBLIC TRUST; REAL VEBA TRUST,
      Appellants

      On Appeal from the United States District Court
      for the Eastern District of Pennsylvania
      (No. 2-11-cv-05275)
      District Judge: Honorable Mary A. McLaughlin

      Submitted Pursuant to Third Circuit L.A.R. 34.1(a)
      March 19, 2013

      ____________

      Before: FUENTES, CHAGARES, and BARRY, Circuit Judges.

      (Filed: June 7, 2013)

      ____________

      OPINION

      ReplyDelete


    8. Some 419 Insurance Welfare Benefit Plans Continue To Get Accountants Into Trouble
      Home Finance Tax
      By: Lance Wallach Email Article
      Word Count: 592 Digg it | Del.icio.us it | Google it | StumbleUpon it




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

      Lance Wallach | Aug 2, 2010

      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.

      In Notice 2007-84, the Service expressed concern with plans that provide all or a substantial portion of benefits to owners and/or key and highly compensated employees. The notice identified numerous specific concerns, among them:

      1. The granting of loans to participants
      2. Providing deferred compensation
      3. Plan terminations that result in the distribution of assets rather than being used post-retirement, as originally established.
      4. Permitting the transfer of life insurance policies to participants.

      Alternative tax treatment may well be in the offing for such arrangements, as the IRS intends to re-characterize such arrangements as dividends, non-qualified deferred compensation (under IRC Section 404(a)(5) or Section 409A), split-dollar life insurance arrangements, or disqualified benefits pursuant to Section 4976. Taxpayers participating in these listed transactions should have, in most cases, already disclosed such participation to the Service. Those who have not should do so at the earliest possible moment. Failure to disclose can result in severe penalties – up to $100,000 for individuals and $200,000 for corporations.

      Finally, Revenue Ruling 2007-65 focused on situations where cash value life insurance is purchased on owner employees and other key employees, while only term insurance is offered to the rank and file. These are sold as 419(e), 419A (f)(6), and 419 plans. Life insurance premiums are not inherently tax deductible and authority must be found in Section 79 to justify such a deduction. Section 264(a), in fact, specifically disallows tax deductions for life insurance, at least in some cases. And moreover, the Service declared, interposition of a trust does not change the nature of the transaction.

      Lance Wallach, CLU, ChFC, CIMC, speaks and writes extensively about financial planning, retirement plans, and tax reduction strategies. He speaks at more than 70 national conventions annually and writes for more than 50 national publications. For more information and additional articles on these subjects, visit www.taxadvisorexperts.org or call 516-938-5007.

      The information provided herein is not intended as legal, accounting, financial or any other type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.
      Contact him at 516.938.5007, wallachinc@gmail.com or visit www.taxadvisorexpert.com.

      Article Source: http://www.ArticleBiz.com

      ReplyDelete
      Replies
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    9. Beta 419,Millennium Plan,Bisys,Creative Services Group,Sterling Benefit Plan,Compass 419,Niche 419,CRESP,Sea Nine Veba, American Benefits Trust, National Benefit Plan and Trust, ABT, Professional Benefits Trust Benistar 419 Plan, nova trust, Grist mill trust, Sadi Trust IRS raids, Millennium 419 Plan,Bisys 419,Creative Services Group 419 Plan,Sterling Benefit 419 Plan,CRESP 419,Sea Nine Veba 419, National Benefit Plan and Trust 419, American Benefits Trust 419,ABT 419,Old Mutual, Allmerica Financial, American Heritage Life, Commercial Union Life, National Life of Vermont, Old Line Life, Security Mutual Life, West Coast Life "Grist Mill Trust" "Real Veba""Section 79 GEAR" GEAR" "United Financial Group" "Kenny Hartstein" "Millennium Plan" Kenny Hartstein" "Millennium Plan" "Tom Crosswhite" "Greg Roper""captive insurance" cresp "Ridge Plan" "Professional benefits Trust" "PBT " "Professional Planning Associates" "National Pension Associate" "NPA""Heritage Plan" ""Insurance fraud""pension and benefit plan fraud""insurance company fraud""ECI Pension Services""Pension Professionals of America""ABI""Hartford""AIG""Indy Life""Indianapolis Life""Advantage" Names of People who SOLD: "Kenny Hartstein""Dennis Cunning""Steve Toth""Michael Sonnenberg"Larry Bell""Scott Ridge""Randall Smith""Greg Roper""Tracy Sunderlage""Warren Trust""Joseph Donnelly""Norm Bevan""Judy Carsrud""Dan Carpenter""Ed Waesche" "Tom Crosswhite""David Struckman""George Huff" "Tom Crosswhite" "Greg Roper""Christopher Jarvis" David Mandell" Gen Von Oder Insurance Companies -- need to be 412 AND 419: Hartford 419, Pacific Life 419, PAC Life 419, AVIVA, 419, Indianpolis Life, Penn Mutual419,Bankers Life 419, John Hancock 419, Security Mutual 419, Transamerica 419,Prudential 419, Kansas City Life 419, Mass Mutual419, Guardian 419, Amerus 419, Wells Fargo 419, Fifth Third Bank 419, Arrow Head Trust 419, U.S. Benefits Group, Benefit Plan Advisors, Rex Insurance Service,Advantage,AIG, Old Mutual, Allmerica Financial, American Heritage Life, Commercial Union Life, National Life of Vermont, Old Line Life, Security Mutual Life, West Coast Life
      Delete
      Posted 12th March by Lance Wallach

      14 View comments

      Lance WallachMarch 17, 2014 at 9:05 AM
      sults (0.73 seconds)
      Search Results
      KENNETH ELLIOT: Sea Nine VEBA Important
      kennethelliotkaeinsuranceco.blogspot.com/.../sea-nine-veba-important.ht...‎
      Jan 7, 2014 - Labels: Kae Consulting, Kae Insurance Service, Kenneth Elliot, .... 419 & 412i benefit plan,abusive tax shelters, Lance Wallach Expert Witness
      You +1'd this
      KENNETH ELLIOT - 412i-419 Plans - Blogger
      419plans.blogspot.com/.../412i-419-plans-

      ReplyDelete














    10. Lance Wallach
      Managing Director
      Specializing in the following services:

      "IRS audit appeals"
      U.S. 'Tax Court' cases
      Multinational taxation consulting
      Recovering losses from insurance companies
      & brokerage firms
      Tax shelter analysis
      Pension plan reviews & evaluations
      419 & 412i benefit plan analysis
      419 & 412i plan remediation
      Offshore tax shelter issues
      IRS listed transactions" assistance

      Expert witness testimony for:
      IRS Taxes
      Insurance & retirement plan cases
      The Offices of Lance Wallach
      516-938-5007 Vebaplan.org
      "America's leading tax
      representation firm."(TM)
      Serving
      clients
      nationwide

      Call us today:

      516-938-5007

      Email us at:

      LanWalla@aol.com

      The Lance Wallach Network

      TaxAudit419.com ReportableTransactions Listed Transactions IRS6707Apenalty IRSform8886 TaxAdvisorExperts
      ExpertTaxAdvisors Taxlibrary.us
      Our consulting attorneys, CPAs & ex IRS agents
      have helped our clients
      save hundreds of thousands of dollars
      successfully defending them in lawsuits,
      IRS audits & cutting IRS pe

      ReplyDelete


    11. Our Team Defends Insurance Agents Who Sold 419 and 412i Benefit Plans

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      Specializing in 412i and "419 Plan Help" and "IRS Audit Defense"for Insurance Agents
      The Tax Audit Pros
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      wallachinc@gmail.com









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      ReplyDelete
    12. Beta 419,Millennium Plan,Bisys,Creative Services Group,Sterling Benefit Plan,Compass 419,Niche 419,CRESP,Sea Nine Veba, American Benefits Trust, National Benefit Plan and Trust, ABT, Professional Benefits Trust Benistar 419 Plan, nova trust, Grist mill trust, Sadi Trust IRS raids, Millennium 419 Plan,Bisys 419,Creative Services Group 419 Plan,Sterling Benefit 419 Plan,CRESP 419,Sea Nine Veba 419, National Benefit Plan and Trust 419, American Benefits Trust 419,ABT 419,Old Mutual, Allmerica Financial, American Heritage Life, Commercial Union Life, National Life of Vermont, Old Line Life, Security Mutual Life, West Coast Life "Grist Mill Trust" "Real Veba""Section 79 GEAR" GEAR" "United Financial Group" "Kenny Hartstein" "Millennium Plan" Kenny Hartstein" "Millennium Plan" "Tom Crosswhite" "Greg Roper""captive insurance" cresp "Ridge Plan" "Professional benefits Trust" "PBT " "Professional Planning Associates" "National Pension Associate" "NPA""Heritage Plan" ""Insurance fraud""pension and benefit plan fraud""insurance company fraud""ECI Pension Services""Pension Professionals of America""ABI""Hartford""AIG""Indy Life""Indianapolis Life""Advantage" Names of People who SOLD: "Kenny Hartstein""Dennis Cunning""Steve Toth""Michael Sonnenberg"Larry Bell""Scott Ridge""Randall Smith""Greg Roper""Tracy Sunderlage""Warren Trust""Joseph Donnelly""Norm Bevan""Judy Carsrud""Dan Carpenter""Ed Waesche" "Tom Crosswhite""David Struckman""George Huff" "Tom Crosswhite" "Greg Roper""Christopher Jarvis" David Mandell" Gen Von Oder Insurance Companies -- need to be 412 AND 419: Hartford 419, Pacific Life 419, PAC Life 419, AVIVA, 419, Indianpolis Life, Penn Mutual419,Bankers Life 419, John Hancock 419, Security Mutual 419, Transamerica 419,Prudential 419, Kansas City Life 419, Mass Mutual419, Guardian 419, Amerus 419, Wells Fargo 419, Fifth Third Bank 419, Arrow Head Trust 419, U.S. Benefits Group, Benefit Plan Advisors, Rex Insurance Service,Advantage,AIG, Old Mutual, Allmerica Financial, American Heritage Life, Commercial Union Life, National Life of Vermont, Old Line Life, Security Mutual Life, West Coast Life
      Delete
      Posted 12th March by Lance Wallach

      16 View comments

      Lance WallachMarch 17, 2014 at 9:05 AM
      sults (0.73 seconds)
      Search Results
      KENNETH ELLIOT: Sea Nine VEBA Important
      kennethelliotkaeinsuranceco.blogspot.com/.../sea-nine-veba-important.ht...‎
      Jan 7, 2014 - Labels: Kae Consulting, Kae Insurance Service, Kenneth Elliot, .... 419 & 412i benefit plan,abusive tax shelters, Lance Wallach Expert Witness
      You +1'd this
      KENNETH ELLIOT - 412i-419 Plans - Blogger
      419plans.blogspot.com/.../412i-419-plans-kenneth-elliot-sea-nine.html‎
      Mar 7, 2014 - 412i-419 Plans: KENNETH ELLIOT: Sea Nine VEBA Important. 412i-419 Plans: KENNETH ELLIOT: Sea Nine VEBA Important: KENNETH ...

      ReplyDelete
    13. About Mr. Wallach
      The leading expert on Employee Benefit plans (VEBA, 419, 412i, 501c); Life insurance, Estates, Trusts & Pensions
      20+ Years Professional Experience
      Member of the AICPA faculty of teaching professionals
      Chartered Life Underwriter
      Chartered Financial Consultant
      AICPA Author & Instructor

      ReplyDelete
    14. Section 79 Plans
      412i, 419e plans litigation and IRS Audit Experts for abusive insurance reportable or listed transactions by the IRS,Section 79, Section 79 Lawsuits,412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.Benistar,412i Lawsuits,419 lawsuits,412i Help,419 Help, IRS Audits,412i Problems,412i problems, Expert Witness Lance Wallach,412i Help,419 Help, Benistar Lawsuits, 412i lawsuits,419 lawsuits,

      Thursday, December 19, 2013

      419, 412i, and Section 79 Investment Plans
      419, 412i, and Section 79 Investment Plans

      If your CPA, financial advisor, or insurance agent introduced you to one of these plans and now the IRS is after you, contact us immediately. You may be a victim of insurance fraud. We want to help protect your business and your hard-earned income.
      Likewise, if you currently participate in one of these plans, and are worried about whether the IRS will penalize you, give us a call. We can help you make sure your plan is legit, and that no one tried to trick you in order to get a huge commission.
      How your CPA, financial advisor, or insurance agent may be responsible for your audit:
      Improper filing of form 8886

      ReplyDelete
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    15. Help with Common IRS Problems

      Tuesday, January 11, 2011

      Help with Common IRS Problems
      There are many problems you can run into with the IRS. The following is an overview and helpful information on some of these confusing issues.

      · IRS Penalties
      · Unfiled Tax Returns
      · IRS Liens
      · IRS Audits
      · Payroll Tax Problems
      · IRS Levies
      · IRS Seizures
      · Wage Garnishments

      IRS Penalties

      The penalizes millions of taxpayers each year. They have so many penalties that it's hard to understand which penalty they are hitting you with.

      The most common penalties are Failure to File and Failure to Pay. Both of these penalties can substantially increase the amount you owe the IRS in a very short period of time.

      To make matters worse the IRS charges you interest on penalties. Many tax-payers often find out about IRS problems many years after they have occurred. This causes the amount owed the IRS to be substantially greater due to penalties and the accumulated interest on those penalties.

      Some IRS penalties can be as high as 75%-100% of the original taxes owed. Often taxpayers can afford to pay the taxes owed, however, the extra penalties make it impossible to pay off the entire balance.

      The original goal of the IRS imposing penalties was to punish taxpayers in order to keep them in line. Unfortunately, the penalties have turned into additional sources of income for the IRS. So they are happy to add whatever penalties they can and to pile interest on top of those penalties. Your loss is their gain.

      Under certain circumstances the IRS does abate, or forgive, penalties. Therefor

      ReplyDelete
    16. 21st Century Insurance
      Acuity
      ACE Limited
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      American Family Insurance
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      American International Group (AIG)
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      Ameritas Life Insurance Company
      Amica Mutual Insurance
      Applied Underwriters
      Arbella Insurance Group
      Assurant
      Assurity Life Insurance Company
      Auto-Owners Insurance
      AXA Equitable Life Insurance Company
      Bankers Life and Casualty Company
      Berkshire Hathaway
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      Cincinnati Insurance Company
      CNA Financial
      Colonial Life & Accident Insurance Company
      Combined Insurance
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      Country Financial
      Chartis
      Chubb Corp.
      Elephant.com
      Encompass Insurance Company
      Erie Insurance Group
      Esurance
      Evergreen USA RRG
      FM Global
      Family Heritage
      Farmers Insurance Group
      Federated Mutual Insurance Company
      First Catholic Slovak Ladies Association of the United States of America
      FirstComp Insurance Company
      First Insurance Company of Hawaii
      GAINSCO

      ReplyDelete

    17. It could be you.

      I am a Third Party Administrator and am asking for your help. One of my clients with 4 employees who
      simply funded a retirement plan with $500,000 recently endured a 5.5 year IRS audit of his 412 (i)
      pension plan. Upon completion of the audit the client owes $55,000 in income taxes for 2004-2006 and
      has refunds from 2007-2008 of $55,000 (timing difference only) He owes about $30,000 in blackmail
      money (He really should owe nothing!). The SBSE income tax agent has threatened to assess $800,000
      in penalties under Code Section 6707a. The IRS is far exceeding their authority in assessing the 6707a
      penalty this is totally prosecutorial abuse. WE must put a stop to this! My client cooperated and acted in
      good faith and did file the form 8886 (Maybe not 100% correctly but none the less, he did file the
      necessary forms).……

      Dennis Cunning

      ReplyDelete
    18. 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 more than 20 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 witnes

      ReplyDelete
    19. Protecting Clients
      from Fraud, Incompetence and Scams

      Every financial expert out there knows that bad faith and bad planning can take down even the biggest firms, wiping out millions of dollars of value in an instant.
      Whether it’s internal fraud, a scammer, or an incompetent planner that takes your client’s cash, the bottom line is: that the money is gone and the loss should have been prevented.

      Filled with authoritative advice from financial expert Lance Wallach, Protecting Clients from Fraud, Incompetence, and Scams equips you as an accountant, attorney, or financial planner with the weaponry you need to detect bad investments before they happen and protect your clients’ wealth- as well as your own.

      Sharp and Savvy in its frank, often humorous, and authoritative examination of financial fraud and mismanagement, you’ll learn about the dysfunctional sectors in the financial industry and:

      • Protecting your retirement assets
      • Asset protection basics
      • Shifting the risk equation: insurance maneuvers
      • Reevaluating existing insurance
      • What financial advisors and insurance agents “forget” to tell their clients
      • The truth about variable annuities
      • What you must know about life settlements
      • The smart way to approach college funding

      A pragmatic blueprint for identifying trouble spots you can expect and immediately useful solutions, Protecting Clients from Fraud, Incompetence, and Scams equips you with the resources, strategies, and tools you need to effectively protect your clients from frauds and financial scammers.


      Lance Wallach, CLU, CHFC, is a leading speaker on accounting and taxation topics and the author of numerous AICPA CPE exam publications. In addition to developing CPE courses, he is also a member of the AICPA faculty of teaching professionals, and has been featured in the Wall Street Journal, the New York Times, Bloomberg Financial News, NBC, National Public Radio’s All Things Considered, and other radio talk shows. Mr. Wallach is listed in Who’s Who in Finance and Business.

      ReplyDelete
    20. Great post, I appreciate you and I would like to read your next post. Thanks for sharing this useful information.
      Aim financial news
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      Blur Group
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      ReplyDelete

    21. Subscribe
      Advertise with Us
      July 15, 2007
      The Newspaper of the NYSSCPA
      Vol. 10, No.13
      IRS Clarifies Legality of 419(e) Plans
      By Lance Wallach, CLU, ChFC, CIMC, and Ron Snyder, JD, EA

      Following the U.S. Congress’ lead, on April 10 the IRS issued final regulations under Section 409A of the Internal Revenue Code. If the rules seemed unclear before, they are crystal clear now: Most of the so-called “419(e)” plans as well as the remaining 419A(f)(6) plans are in violation of the law and subject to hefty penalties.

      A 419(e) plan is a benefit plan that generally seeks to make the purchase of life insurance tax-deductible to employers. While the concept is appealing, most of the existing arrangements have permitted the plans to transfer the insurance policies to the participants upon retirement.

      The Purpose of 409A

      Code Section 409A was enacted into law on Oct. 10, 2004, to pr

      ReplyDelete
    22. Home
      About Us
      In The Press
      Contact Us
      ABOUT LANCE WALLACH

      Click Here now
      KNOWLEDGE

      You need someone on your side.
      SERVING CLIENTS NATIONWIDE
      516-938-5007 OR 516-935-7346


      Everyone of Our Consulting Attorneys,CPA's and Ex IRS Agents has over 25 years of experience!

      No firm has more Experienced Professionals to Assist Their Clients Than We do.
      Share on facebookShare on twitterShare on google_plusone_share
      Lance Wallach

      Read More
      Read More
      LANCE WALLACH WROTE THE BOOK- DO YOU WANT ASSISTANCE FROM THE STUDENT OR THE TEACHER

      ReplyDelete
    23. The Office of Lance Wallach
      Articles
      "America's leading tax representation firm."(TM)

      Every one of our
      consulting attorneys, has
      over 25 years of
      professional
      experience!

      We believe that no firm
      has more experienced
      professionals to assist
      our clients than we do!!

      Lance Wallach
      Managing Director

      ReplyDelete
    24. Accountantexpert.Org



      CAUTION:

      IRS is attacking 419 plans, 419, 412i, 412(e)(3), Section 79,

      Captive Insurance,

      many other benefit plans, and plans having life insurance.

      ReplyDelete
      Replies
      1. This comment has been removed by the author.

        Delete
    25. http://taxaudit419.com/Article-44-BruceHink-ProtectingClientsBookExcerpt.html

      ReplyDelete
    26. This comment has been removed by the author.

      ReplyDelete
    27. Before you buy you should know section 79 Plan history
      section79plans.org
      Section 79 Scams and Captive Insurance History

      When trying to understand how a product becomes a target of government scrutiny it helps to know its history.

      In the case of plans that fall under Internal Revenue Code Section 79, that history is complex.

      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, in addition to being charged penalties and interest. A skilled CPA with extensive IRS experience could usually eliminate the penalties and reduce the fines. Most accountants, tax attorneys and others have been unsuccessful in accomplishing this.

      Follow the link to learn more about Section 79 Plans.
      lancewallachlawsuits
      412i412412i PlanLance WallachLance Wallach Expert WitnessExpert WitnessExpert Witness Testimony419419 PlanIRSIRS AuditsIRS Audit AppealsTax litigationtax resolution servicesSection 79Section 79 PlansSection 79 Plan History
      1 note
      Abusive Insurance and Retirement Plans
      taxaudit419.com
      Single-employer section 419 welfare benefit plans are the latest incarnation in insurance deductions the IRS deems abusive.

      EXECUTIVE SUMMARY

      ReplyDelete
    28. This comment has been removed by the author.

      ReplyDelete
    29. Expert Witness Directory
      ABOUT THE AUTHOR: Lance Wallach
      Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, Wallach is a frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters. He is also a featured writer and has been interviewed on television and financial talk shows including NBC, National Public Radio’s All Things Considered and others. Lance authored 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.

      Copyright Lance Wallach, CLU, CHFC

      More information about Lance Wallach, CLU, CHFC


      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.

      ReplyDelete
    30. Lance Wallach” “419 welfare benefit plans” “412i retirement plans” “412i” “tax
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      Abusive Welfare Benefit and
      Retirement Plans Can Lead to
      Severe Penalties for Accountants

      By Lance Wallach
      Lance Wallach, 419 welfare benefit plans, 412i retirement plans, 412i, tax shelter litigation, abusive tax shelters, fight tax shelter penalty, Bankers Life, Hartford Life,
      CRESP, American General Life, Bisys, Benistar, United Financial Group, Grist Mill Trust
      Accountants who are unaware of recent developments are likely to encounter a nightmarish
      scenario that may play out something like this: you sign a client’s tax return that claims a tax

      ReplyDelete
    31. This comment has been removed by the author.

      ReplyDelete
    32. Home
      About
      Services
      Contact
      Video and Testimonials

      Section 79 Help

      Lance wallach expert witness expert witness services
      Most people have never heard of a Section 79 plan because, it is a wealth building tool pitched by insurance agents who really do not understand the math behind the plan. Section 79 plans can cause people huge problems that Lance Wallach knows how to help solve.
      Remember, many advisory firms offer financial planning, insurance, and investment services, but the difference is that Lance Wallach wrote the books on life insurance as well as financial and estate planning that the other consultants learn from! If you want to sleep soundly at night, don;t go to the students for your financial solutions, go to the one who teaches them.-Lance Wallach.
      EXPERT WITNESS SERVICES
      Changes to Reporting under 6707A
      11/28/2014, 12:34:00 PM
      January 15, 2010: Brand New Update: The new proposed regulations specify a requirement that reporting forms filed under 6707A ...
      Challenges to 6707A Penalties
      11/26/2014, 12:33:00 PM
      Is IRS Section 6707A Fair? Even the IRS personnel continue to question both the legality and the fairness of the IRS’s ...
      Is 6707A Constitutional?

      ReplyDelete
    33. This comment has been removed by the author.

      ReplyDelete

    34. Wednesday, May 14, 2014
      6707a Listed Transactions
      6707a Listed Transactions
      Posted by Lance Wallach at 12:30 PM
      Email This
      BlogThis!
      Share to Twitter
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      2 comments:

      Lance WallachJune 30, 2014 at 5:30 AM
      Indian American’s tax scheme that promised benefits, loans on life insurance has the DoJ frowning
      April 23, 2014

      Court bars Ramesh Sarva from the scheme.

      By Deepak Chitnis

      WASHINGTON, DC: Ramesh Sarva, a Certified Public Accountant (CPA) in New York, has been barred from actively promoting a nationwide tax scheme he allegedly was pitching to clients of his.

      A US federal court said on Tuesday that Sarva could no longer try and sign clients up for the apparently illegal scheme, the details of which sound almost too good to be true. Sarva, who resides in Little Neck, New York, has agreed to the injunction levied against him by Judge Josephine L. Station, of the US District Court for the Central District of California.



      According to the Department of Justice, Sarva sold his customers a life insurance welfare benefits plan that allowed them to unlawfully claim significant tax deductions that they were unqualified for. On top of that, these people would have access to the entire value of the contributions they made towards their life insurance policy, by taking out loans against it.

      “Sarva’s promotion of these unlawful welfare benefit plans deprived the U.S. Treasury of significant amounts of tax and subjected his customers to audits and IRS scrutiny,” said the Department of Justice, in a press release.

      The injunction against Sarva bars him from promoting and selling any kind of welfare benefit plans. Additionally, Sarva will have to furnish the US government with a list of all of his customers, regardless of if they were part of this life insurance tax scheme, and Sarva will have to send a copy of the injunction to all of his customers, so that they are aware of his

      ReplyDelete

      Lance WallachDecember 10, 2014 at 4:17 AM
      Business Valuations.org Call Lance Wallch at 516-938-5007
      Skip to content
      Home
      ← Chapter One MeltdownNew BISK CPEasy™ CPE Self-Study Course →
      America’s Best-selling CPE Programs Business Valuations
      Posted on February 24, 2014 by Admin


      America’s Best-selling CPE Programs

      Business Valuations: What Businesses Can Gain From Them

      A business valuation measures the worth of a business on the open market. It analyzes the company’s management, capital structure, future earnings potential and market value of its assets – and can be critical to running a successful enterprise.



      Business valuations are often performed during a sale, merger or divorce proceeding. But every business can benefit from an annual valuation. After all, a business is

      ReplyDelete








    35. Copyright (C) 2010 - Lance Wallach

      Our team of experienced consulting "tax attorneys", CPAs, and "insurance experts" specializing in 412i" and "419 "IRS
      audits" that resulted from plans you sold to your clients, mainly "419 plans", "412i plans", "captive insurance" plans
      and "Section 79" plans as well as other similar "employee benefit plans" or "welfare benefit plans" that the IRS is
      targeting as "abusive tax shelters".

      Our firm has been successful in "defending life insurance agents" and "material advisors" who have participated in
      the sale of these "benefit plans".

      If you signed a return or participated in the sale of these "welfare benefit plans", you are probably a "material
      advisor" and subject to huge "IRS penalties and interest". No "Form 8886" or "Form 8918" that we have reviewed for
      new clients has been properly prepared, which leaves the "material advisor" subject to the $200,000 "IRS penalty".

      We fight for our clients to defend against the $200,000 IRS "6707A penalty" by providing "expert witness
      testimony". Lance's side has never lost a case!

      ReplyDelete
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      ReplyDelete