tag:blogger.com,1999:blog-4462792519972887259.post6320730042285496055..comments2023-06-20T11:53:02.176-04:00Comments on We Want to Profile You in New Book: New Transaction of Interest - Charitable Remainder Trust Interestsirsdoghttp://www.blogger.com/profile/09151038267411467771noreply@blogger.comBlogger2125tag:blogger.com,1999:blog-4462792519972887259.post-29428498463867119592014-06-17T07:59:49.847-04:002014-06-17T07:59:49.847-04:00412i 419E IRS Audits and Problems
412i, 419e plans...412i 419E IRS Audits and Problems<br />412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.<br />Tuesday, April 17, 2012<br /><br />412i Tax Shelter Fraud Litigation - How It Works<br /><br />Lance Wallach<br /> <br />PARTIES:<br />Typically, these transactions will include an Insurance company, accountant, tax attorney, and a promoter (someone with an insurance background, perhaps an actuary, who knows how to structure the policy itself). These groups will use insurance brokerages and sub-agents (licensed in the various states) to sell the policies themselves. <br /><br />INSURANCE COMPANIES<br />AMERICAN GENERAL LIFE INSURANCE COMPANY® INDIANAPOLIS LIFE INSURANCE COMPANY®<br />HARTFORD LIFE AND ANNUITY INSURANCE COMPANY® PACIFIC LIFE INSURANCE COMPANY®<br /> BANKERS LIFE and OTHERS®?<br /><br />4121iHOW THESE PLANS WORK:<br />In the late 1990’s, 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.<br />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.<br />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.<br />The policies that were sold were termed Springing Cash Value Policies. They had 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 purchases the policy from the trust for the policy’s surrender value. In theory, you have a tax free transaction.<br />The IRS does not recognize the tax benefit of such a plan and has repeatedly issued annLance Wallachhttps://www.blogger.com/profile/05541601942749133861noreply@blogger.comtag:blogger.com,1999:blog-4462792519972887259.post-46326532911093709352014-06-12T07:33:59.185-04:002014-06-12T07:33:59.185-04:00412i 419 sect 79 lawsuits audits www.lancewallach....412i 419 sect 79 lawsuits audits www.lancewallach.com for help (plainview)<br /><br /><br />© craigslist - Map data © OpenStreetMap<br />(google map) (yahoo map)<br /><br />compensation: no pay<br />Lance Wallach helps with 419 problems. 412i 419 abusive tax shelters IRS audits, lawsuits, Lance Wallach will help www.vebaplan.com<br />419, 412i, IRS audits, Lance Wallach, Google him helps, The following had something to do with this.<br />Dennis Cunning Steve Toth Randall Smith Paul Kaplan Herb Green Casey Hermansen<br />Larry Bell Scott Ridge Judy Carsrud Jeffrey Glasberg Herb McDowel <br />Greg Roper Joseph Donnelly<br />Norm Bevan Michael Sonnenberg <br />r Anthony Fakouri<br />Steve Burgess<br />Robin Weingast <br />IRS audits 419 412i captive insurance and section 79 plans. Lance Wallach will help you.<br /><br />IRS audits section 79 419 412i plans. www.lancewallach.com for help<br />Benistar, 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.<br />Sea Nine VEBA, 419,412i are all IRS audit targets. Lance Wallach can help, www.tazaudit419.com <br />419, 412i, IRS audits, Lance Wallach, Google him helps, The following had something to do with this. Author to write about these problems.<br />Dennis Cunning Steve Toth Randall Smith Paul Kaplan Herb Green Casey Hermansen<br />Larry Bell Scott Ridge Judy Carsrud Jeffrey Glasberg Herb McDowel <br />Greg Roper Joseph Donnelly<br />Norm Bevan Michael Sonnenberg <br />Anthony Fakouri<br />Steve Burgess<br />Robin Weingast <br />" Lance Wallach will help fix the problems that people have that are or were in the plans.<br />"Professional Benefits Trust" PBI<br /><br />"Sea Nine Veba" <br />Bisys <br />The "Beta Plan" <br />The "Millennium Plan" <br /><br />Niche <br />The "Ridge Plan"<br /><br /><br />The "Compass Welfare Benefit Plan" <br />"Section 79 Plans" <br />"Captive Insurance" <br />and other similar "412i retirement plans" and "419 welfare benefit plans <br /><br />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.<br /><br />Customers of James Cunningham d/b/a Cunningham Financial or CFG Consulting LLC? We want to speak with you!<br />IRS audits and lawsuits result from 419 412i captive insurance and section 79 plans. As an expert witness Lance Wallach has never lost a caseLance Wallachhttps://www.blogger.com/profile/05541601942749133861noreply@blogger.com