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| California Enrolled Agent How to Get Fined $100,000 by the IRS and Lose Your License By Lance Wallach, CLU, ChFC and Ira Kaplan, Esq., CPA, MBA Over the past decade, business owners have been overwhelmed by a plethora of arrangements designed to reduce the cost of providing employee benefits and taxes, while simultaneously increasing their own retirement savings. The solutions ranged from traditional pension and profit sharing plans to more advanced strategies. Some strategies, such as IRS Section 419 and 412(i) plans, used life insurance as vehicles to bring about benefits. Unfortunately, the high life insurance commissions (often 90% of the contribution, or more) fostered an environment that led to the marketing and selling of aggressive and noncompliant plans. Read More |
New and Bestselling
AICPA CPE Self-Study Courses
Avoiding Circular 230 Malpractice Traps and Common Abusive Small
Business Hot Spots, by Sid Kess
Author/Moderator: Lance Wallach, CLU, CHFC,
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. Read More
AICPA CPE Self-Study Courses
Avoiding Circular 230 Malpractice Traps and Common Abusive Small
Business Hot Spots, by Sid Kess
Author/Moderator: Lance Wallach, CLU, CHFC,
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. Read More
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National Society of Accountants
Captive Insurance and Other Tax Reduction Strategies – The Good, Bad,
and Ugly
By Lance Wallach
Every accountant knows that increased cash flow and cost savings are critical for
businesses in 2008. What is uncertain is the best path to recommend to garner
these benefits.
Over the past decade business owners have been overwhelmed by a plethora of
choices designed to reduce the cost of providing employee benefits while increasing
their own retirement savings. The solutions ranged from traditional pension and
profit sharing plans to more advanced strategies.
Some strategies, such as IRS section 419 and 412(i) plans, used life insurance as
vehicles to bring about benefits. Unfortunately, the high life insurance commissions
(often 90% of the contribution, or more) fostered an environment that led to
aggressive and non-compliant plans.
Read More
National Society of Accountants
Captive Insurance and Other Tax Reduction Strategies – The Good, Bad,
and Ugly
By Lance Wallach
Every accountant knows that increased cash flow and cost savings are critical for
businesses in 2008. What is uncertain is the best path to recommend to garner
these benefits.
Over the past decade business owners have been overwhelmed by a plethora of
choices designed to reduce the cost of providing employee benefits while increasing
their own retirement savings. The solutions ranged from traditional pension and
profit sharing plans to more advanced strategies.
Some strategies, such as IRS section 419 and 412(i) plans, used life insurance as
vehicles to bring about benefits. Unfortunately, the high life insurance commissions
(often 90% of the contribution, or more) fostered an environment that led to
aggressive and non-compliant plans.
Read More
--------------------------------------------------------------------------------------------------
Commercial Flooring Report
How to Find the Right Experts to Guide You Through These Times
These days, business owners have a lot on their plates. Not only do they have
businesses to run, but they need to have the resources to operate, manage,
and flourish those businesses in order to stay afloat. Without serious
knowledge of things like finances, taxes, tax audits, and retirement plans, it's
hard to keep a shop open for business and to ensure that your future is in
good hands. Especially now, as the economy begins to change, it is smart to
look into different ways to secure your future and money. Recent well
documented events have made it increasingly important to educate yourself on
how to handle such endeavors correctly. Thousands of businesses have
closed as a result of bankruptcy, corrupt policies, lowered sales, and other
factors, often because issues that seemingly, in hindsight, should have been
obvious were overlooked. In this environment, more than ever, you simply
cannot afford mistakes or omissions with respect to your finances. Such
mistakes can result in audits and other problems that could eventually lead to
the closing of your establishment. Being aware of the amount of debt that you
are carrying, when your sales tend to plummet, and your number of employees
are three trivial yet important aspects of watching your money. Websites such
as IRS.gov, FinanceExperts.org, and TaxLibrary.us are resources that can
help make sure that there are ZERO unpleasant surprises in your numbers.
Additionally, keeping accurate records and constantly double checking your
numbers are two obvious, yet often neglected, things that you should do. So
the question stands: how knowledgeable are you about your own finances?
Read more
“abusive tax shelter help” "tax letter" "irs letter" "irs letters" "irs determination letter" 419e 412i 6707a "form 8886" "listed transactions"
"abusive tax shelter assistance" "irs penalty abatement" "expert witness irs" veba "expert witness services" "expert witness irs help"
"pension audit" "Grist Mill Trust" Benistar "SADI Trust" "Beta 419" "Millennium Plan" Bisys "Creative Services Group" "Sterling
Benefit Plan" "Compass 419" Niche "Sea Nine Veba" 419 412i 419e "expert witness insurance" "welfare benefit plans" "419 plan help"
"expert witness irs" “abusive tax shelter help” “irs appeal” “tax resolution services” “insurance expert witnesses” “pension plan audit”
“tax preparer penalties” “tax audit defense” “business tax audit” “tax penalty abatement” “irs tax problems” “circular 230” “retirement
tax shelters” “health insurance fraud” “employer insurance fraud” “irs trouble” “unfiled tax returns” “unfiled taxes” 419 412i "listed
transactions" "form 8886" 6707A "tax shelters" "IRS audit defense" "expert witness irs help" "welfare benefit plan help" "419 plan help"
"irs penalty abatement" "fight the irs" "412i retirement plans" "tax resolution services" "irs problem solvers" "how to avoid irs audit"
"abusive tax shelter help"
Commercial Flooring Report
How to Find the Right Experts to Guide You Through These Times
These days, business owners have a lot on their plates. Not only do they have
businesses to run, but they need to have the resources to operate, manage,
and flourish those businesses in order to stay afloat. Without serious
knowledge of things like finances, taxes, tax audits, and retirement plans, it's
hard to keep a shop open for business and to ensure that your future is in
good hands. Especially now, as the economy begins to change, it is smart to
look into different ways to secure your future and money. Recent well
documented events have made it increasingly important to educate yourself on
how to handle such endeavors correctly. Thousands of businesses have
closed as a result of bankruptcy, corrupt policies, lowered sales, and other
factors, often because issues that seemingly, in hindsight, should have been
obvious were overlooked. In this environment, more than ever, you simply
cannot afford mistakes or omissions with respect to your finances. Such
mistakes can result in audits and other problems that could eventually lead to
the closing of your establishment. Being aware of the amount of debt that you
are carrying, when your sales tend to plummet, and your number of employees
are three trivial yet important aspects of watching your money. Websites such
as IRS.gov, FinanceExperts.org, and TaxLibrary.us are resources that can
help make sure that there are ZERO unpleasant surprises in your numbers.
Additionally, keeping accurate records and constantly double checking your
numbers are two obvious, yet often neglected, things that you should do. So
the question stands: how knowledgeable are you about your own finances?
Read more
“abusive tax shelter help” "tax letter" "irs letter" "irs letters" "irs determination letter" 419e 412i 6707a "form 8886" "listed transactions"
"abusive tax shelter assistance" "irs penalty abatement" "expert witness irs" veba "expert witness services" "expert witness irs help"
"pension audit" "Grist Mill Trust" Benistar "SADI Trust" "Beta 419" "Millennium Plan" Bisys "Creative Services Group" "Sterling
Benefit Plan" "Compass 419" Niche "Sea Nine Veba" 419 412i 419e "expert witness insurance" "welfare benefit plans" "419 plan help"
"expert witness irs" “abusive tax shelter help” “irs appeal” “tax resolution services” “insurance expert witnesses” “pension plan audit”
“tax preparer penalties” “tax audit defense” “business tax audit” “tax penalty abatement” “irs tax problems” “circular 230” “retirement
tax shelters” “health insurance fraud” “employer insurance fraud” “irs trouble” “unfiled tax returns” “unfiled taxes” 419 412i "listed
transactions" "form 8886" 6707A "tax shelters" "IRS audit defense" "expert witness irs help" "welfare benefit plan help" "419 plan help"
"irs penalty abatement" "fight the irs" "412i retirement plans" "tax resolution services" "irs problem solvers" "how to avoid irs audit"
"abusive tax shelter help"
 |
| |
 |
| |
 |
| |
 |
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Journal of Accountancy
Abusive Insurance and Retirement Plans
Single-employer section 419 welfare benefit plans are the latest
incarnation in insurance deductions the IRS deems abusive.
by Lance Wallach
Parts of this article are from the AICPA CPE self-study course Avoiding Circular 230
Malpractice Traps and Common Abusive Small Business Hot Spots, by Sid Kess,
authored by Lance Wallach.
Many of the listed transactions that can get your clients into trouble with the
IRS are exotic shelters that relatively few practitioners ever encounter. When
was the last time you saw someone file a return as a Guamanian trust (Notice
2000-61)? On the other hand, a few listed transactions concern relatively
common employee benefit plans the IRS has deemed tax-avoidance schemes
or otherwise abusive. Perhaps some of the most likely to crop up, especially in
small business returns, are arrangements purporting to allow deductibility of
premiums paid for life insurance under a welfare benefit plan. Read More
“abusive tax shelter help” "tax letter" "irs letter" "irs letters" "irs determination letter" 419e 412i 6707a "form 8886" "listed transactions" "abusive tax
shelter assistance" "irs penalty abatement" "expert witness irs" veba "expert witness services" "expert witness irs help" "pension audit" "Grist Mill
Trust" Benistar "SADI Trust" "Beta 419" "Millennium Plan" Bisys "Creative Services Group" "Sterling Benefit Plan" "Compass 419" Niche "Sea
Nine Veba" 419 412i 419e "expert witness insurance" "welfare benefit plans" "419 plan help" "expert witness irs" “abusive tax shelter help” “irs
appeal” “tax resolution services” “insurance expert witnesses” “pension plan audit” “tax preparer penalties” “tax audit defense” “business tax audit”
“tax penalty abatement” “irs tax problems” “circular 230” “retirement tax shelters” “health insurance fraud” “employer insurance fraud” “irs trouble”
“unfiled tax returns” “unfiled taxes” 419 412i "listed transactions" "form 8886" 6707A "tax shelters" "IRS audit defense" "expert witness irs help"
"welfare benefit plan help" "419 plan help" "irs penalty abatement" "fight the irs" "412i retirement plans" "tax resolution services" "irs problem
solvers" "how to avoid irs audit" "abusive tax shelter help"
Journal of Accountancy
Abusive Insurance and Retirement Plans
Single-employer section 419 welfare benefit plans are the latest
incarnation in insurance deductions the IRS deems abusive.
by Lance Wallach
Parts of this article are from the AICPA CPE self-study course Avoiding Circular 230
Malpractice Traps and Common Abusive Small Business Hot Spots, by Sid Kess,
authored by Lance Wallach.
Many of the listed transactions that can get your clients into trouble with the
IRS are exotic shelters that relatively few practitioners ever encounter. When
was the last time you saw someone file a return as a Guamanian trust (Notice
2000-61)? On the other hand, a few listed transactions concern relatively
common employee benefit plans the IRS has deemed tax-avoidance schemes
or otherwise abusive. Perhaps some of the most likely to crop up, especially in
small business returns, are arrangements purporting to allow deductibility of
premiums paid for life insurance under a welfare benefit plan. Read More
“abusive tax shelter help” "tax letter" "irs letter" "irs letters" "irs determination letter" 419e 412i 6707a "form 8886" "listed transactions" "abusive tax
shelter assistance" "irs penalty abatement" "expert witness irs" veba "expert witness services" "expert witness irs help" "pension audit" "Grist Mill
Trust" Benistar "SADI Trust" "Beta 419" "Millennium Plan" Bisys "Creative Services Group" "Sterling Benefit Plan" "Compass 419" Niche "Sea
Nine Veba" 419 412i 419e "expert witness insurance" "welfare benefit plans" "419 plan help" "expert witness irs" “abusive tax shelter help” “irs
appeal” “tax resolution services” “insurance expert witnesses” “pension plan audit” “tax preparer penalties” “tax audit defense” “business tax audit”
“tax penalty abatement” “irs tax problems” “circular 230” “retirement tax shelters” “health insurance fraud” “employer insurance fraud” “irs trouble”
“unfiled tax returns” “unfiled taxes” 419 412i "listed transactions" "form 8886" 6707A "tax shelters" "IRS audit defense" "expert witness irs help"
"welfare benefit plan help" "419 plan help" "irs penalty abatement" "fight the irs" "412i retirement plans" "tax resolution services" "irs problem
solvers" "how to avoid irs audit" "abusive tax shelter help"
--------------------------------------------------------------
California Enrolled Agent
Abusive 412(i) Retirement Plans Can Get Accountants Fined $200,000
By Lance Wallach & Ira Kaplan, Esq.
plans. The large insurance commissions generate some of the enthusiasm. Unlike
other retirement plans, the 412(i) plan must have insurance products as the
funding mechanism. This seems to generate enthusiasm among insurance
agents. The IRS has been auditing almost all participants in 412(i) plans for the
last few years. At first, they thought all 412(i) plans were abusive. Many
participants’ contributions were Most insurance agents sell 412(i) retirement
disallowed and there were additional fines of plans. The large insurance
commissions $200,000 per year for the participants. The accountants who signed
the tax returns (who the IRS called “material advisors”) were also fined $200,000
with a referral to the Office of Professional Responsibility. Read more
.
-----------------------------------------------------------
TAX BRIEFS
ABUSIVE INSURANCE PLANS GET RED FLAG
The IRS in Notice 2007-83 identified as listed transactions certain trust
arrangements involving cash-value life insurance policies. Read More
TAX BRIEFS
ABUSIVE INSURANCE PLANS GET RED FLAG
The IRS in Notice 2007-83 identified as listed transactions certain trust
arrangements involving cash-value life insurance policies. Read More
| Lawyer4Audits.com |
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| Tipping the scales of justice in your favor. |
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| 516 - 938 - 5007 |
| Lawyer4audits professionals write for world renowned publications. Benefit from their advice through these articles. |
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| Lawyer4Audits.com The Law Offices of Mark Levinson, Esq. 516-938-5007 |
| What 412i Fraud Cost These Folks in Audits, Fines, and Penalties Could Happen To You. Are You Prepared? A court case in Jefferson County, West Virginia documents just how bad a 412i case can get in terms of IRS audits, fines, and penalties. This is how several families handled the situation and the millions of dollars at stake. Read more..... |
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IRS Audits Focus on Captive Insurance Plans
April 2011 Edition
By Lance Wallach
The IRS started auditing § 419 plans in the 1990s, and then continued going
after § 412(i) and other plans that they considered abusive, listed, or
reportable transactions, or substantially similar to such transactions. If an IRS
audit disallows the § 419 plan or the § 412(i) plan, not only does the taxpayer
lose the deduction and pay interest and penalties, but then the IRS comes
back under IRC 6707A and imposes large fines for not properly filing. Read
More.
April 2011 Edition
By Lance Wallach
The IRS started auditing § 419 plans in the 1990s, and then continued going
after § 412(i) and other plans that they considered abusive, listed, or
reportable transactions, or substantially similar to such transactions. If an IRS
audit disallows the § 419 plan or the § 412(i) plan, not only does the taxpayer
lose the deduction and pay interest and penalties, but then the IRS comes
back under IRC 6707A and imposes large fines for not properly filing. Read
More.
California Broker, June 2011
Employee Retirement Plans
By Lance Wallach
412i, 419, Captive Insurance and Section
79 Plans; Buyer Beware
The IRS has been attacking all 419 welfare benefit plans, many
412i retirement plans, captive insurance plans with life insurance
in them, and Section 79 plans. IRS is aggressively auditing
various plans and calling them “listed transactions,” “abusive tax
shelters,” or “reportable transactions,” participation in any of
which must be disclosed to the Service. The result has been IRS
audits, disallowances, and huge fines for not properly reporting
under IRC 6707A. Click here to read more. Click here for the
PDF version.
Employee Retirement Plans
By Lance Wallach
412i, 419, Captive Insurance and Section
79 Plans; Buyer Beware
The IRS has been attacking all 419 welfare benefit plans, many
412i retirement plans, captive insurance plans with life insurance
in them, and Section 79 plans. IRS is aggressively auditing
various plans and calling them “listed transactions,” “abusive tax
shelters,” or “reportable transactions,” participation in any of
which must be disclosed to the Service. The result has been IRS
audits, disallowances, and huge fines for not properly reporting
under IRC 6707A. Click here to read more. Click here for the
PDF version.