tag:blogger.com,1999:blog-4462792519972887259.post644388919258547737..comments2023-06-20T11:53:02.176-04:00Comments on We Want to Profile You in New Book: 412i, 419, Lawsuits, IRS Audits. Lance Wallach, expert witness.irsdoghttp://www.blogger.com/profile/09151038267411467771noreply@blogger.comBlogger8125tag:blogger.com,1999:blog-4462792519972887259.post-23877702895634266932016-05-17T16:59:19.728-04:002016-05-17T16:59:19.728-04:00LLC announced that today it filed a class action l...LLC announced that today it filed a class action lawsuit against Chicago-based CJA and Associates and Kansas City, Missouri-based Fidelity Security Life Insurance Company (FSL). The lawsuit alleges that CJA and FSL breached fiduciary duties in duping small business owners into investing millions of dollars of employee retirement benefit money in FSL annuities when up to 95% of the initial money invested was being siphoned off in commissions and fees. The so-called Section 412 (e)(3) plans are under attack from the IRS as illegitimate attempts to avoid federal taxes. The lawsuit alleges that by advising investment in these plans CJA and FSL breached federal laws governing advice given to employee benefit plans.<br /><br />Purchasers of CJA or FSL Section 412 (e)(3) plans are encouraged to contact Anonymoushttps://www.blogger.com/profile/13821166526664300085noreply@blogger.comtag:blogger.com,1999:blog-4462792519972887259.post-30153041872523742222016-05-17T16:58:38.528-04:002016-05-17T16:58:38.528-04:00LLC announced that today it filed a class action l...LLC announced that today it filed a class action lawsuit against Chicago-based CJA and Associates and Kansas City, Missouri-based Fidelity Security Life Insurance Company (FSL). The lawsuit alleges that CJA and FSL breached fiduciary duties in duping small business owners into investing millions of dollars of employee retirement benefit money in FSL annuities when up to 95% of the initial money invested was being siphoned off in commissions and fees. The so-called Section 412 (e)(3) plans are under attack from the IRS as illegitimate attempts to avoid federal taxes. The lawsuit alleges that by advising investment in these plans CJA and FSL breached federal laws governing advice given to employee benefit plans.<br /><br />Purchasers of CJA or FSL Section 412 (e)(3) plans are encouraged to contact Anonymoushttps://www.blogger.com/profile/13821166526664300085noreply@blogger.comtag:blogger.com,1999:blog-4462792519972887259.post-11329689639403927762014-05-12T08:13:56.990-04:002014-05-12T08:13:56.990-04:00CJA And Associates - PRESIDENT
by Anonymous Jul ...CJA And Associates - PRESIDENT<br />by Anonymous Jul 05, 2013 9 comments Review #: 426316<br /> 1 of 2 Cja And Associates Reviews Next →<br />Company CJA And Associates<br />Product / Service Insurance Fraud Negligence<br />Location Naples, Florida<br />Category Financial Scams and Schemes<br />Views 67<br /> <br />CJA SOLD US DEFECTIVE EMPLOYEE BENEFIT PLANS COSTING US HUNDREDS<br />OF THOUSANDS OF DOLLARS AND IRS AUDITS AND PENALTIES<br />ALL WHILE CJA WALKED AWAY WITH HUNDREDS OF THOUSANDS OF OUR DOLLARS IN COMMISSIONS<br />ALSO THE INSURANCE COMPANY FIDELITY SECURITY LIFE INSURANCE IS PART OF THIS SCHEME TO DEFRAUD COMPANIES OUT OF MILLIONS OF DOLLARS<br />THE IRS GOT LIST OF ALL OF CJA CUSTOMERS AND CAME AFTER THEM WITH AUDITS AND HUGE FINES, CJA HAS DONE NOTHING TO RECTIFY THEIR MISTAKE AND REFUSES TO GIVE BACK ANY MONEY OR ANY OF THE COMMISSIONS THEY TOOK AT THEIR CUSTOMERS EXPENSE AND EXPOSURE TO HUNDREDES OF THOUSANDS OF IRS PENALTIES 38366ca<br /> lance wallachhttps://www.blogger.com/profile/05381002998730283542noreply@blogger.comtag:blogger.com,1999:blog-4462792519972887259.post-2666509664900958612014-04-26T06:40:08.424-04:002014-04-26T06:40:08.424-04:00IN THE UNITED STATES DISTRICT COURT
FOR THE EASTER...IN THE UNITED STATES DISTRICT COURT<br />FOR THE EASTERN DISTRICT OF PENNSYLVANIA<br />PENN-MONT BENEFIT SERVICES, INC. :<br />Plaintiff : CIVIL ACTION<br />: NO. 02-1980<br />v. :<br />:<br />THOMAS W. CROSSWHITE, ET AL., :<br />Defendants :<br />MEMORANDUM<br />RUFE, J. January 29, 2003<br />This case is just one of numerous suits involving these parties and their disputes over a<br />troubled business relationship. Before the Court is Defendants’ Motion to Dismiss for Failure to<br />State a Claim. For the reasons set forth below, Defendants’ Motion is granted, and the Amended<br />Complaint is dismissed. <br />I. BACKGROUND<br />As the Court noted in its December 18, 2002 Memorandum, which the Court incorporates<br />herein, the tenor and strain of this case can only be understood by a full explication of the parties’<br />litigious relationship. As it is related below, the factual background of the instant dispute is<br />taken mostly from Plaintiff’s Amended Complaint, as the Court on a motion to dismiss must<br />accept as true the factual allegations therein. <br />When it was originally filed in April 2002, Defendants in this case included four Oregon<br />corporations: The Corben Institute (“Corben”); Cascade Marketing Agency, Inc. (“Cascade”);<br />MJT Marketing, Inc. (“MJT”); Jontiff, Inc. (“Jontiff”); and Welfare Benefit Services, LLC<br />(“WBS”). The other three defendants were all individual citizens of Oregon: Thomas W.<br />Crosswhite (“Crosswhite”); his wife, Barbara J. Crosswhite; and Arnie A. Rigoni (“Rigoni”). 1 Plaintiff’s pleadings are replete with puffery regarding Mr. Koresko’s expert abilities. <br />This Court has no occasion to express any opinion as to Mr. Koresko’s skill in the VEBA arena,<br />and neither this nor any other opinion of this Court should be read as an endorsement or<br />recognition of Mr. Koresko’s alleged VEBA expertise.<br />-2-<br />Crosswhite is the CEO of Corben, President of MJT, and principalance wallachhttps://www.blogger.com/profile/05381002998730283542noreply@blogger.comtag:blogger.com,1999:blog-4462792519972887259.post-37236103439060711032014-04-24T11:08:28.516-04:002014-04-24T11:08:28.516-04:00Recently, there has been an explosion in the marke...Recently, there has been an explosion in the marketing of a financial product called captive insurance. These so called “Captives” are typically small insurance companies designed to insure the risks of an individual business under IRS Code Section 831(b). When properly designed, a business can make tax deductible premium payments to a related party insurance company. Depending on circumstances, underwriting profits, if any, can be paid out to the owners as dividends, and profits from liquidation of the company may be taxed as capital gains. <br /> <br />While captives can be a great cost saving tool, they also are expensive to build and manage. Also, captives are allowed to garner tax benefits because they operate as real insurance companies. Advisors and business owners who misuse captives or market them as estate planning tools, asset protection vehicles, tax deferral or to obtain other benefits not related to the true business purpose of an insurance company face grave regulatory and tax consequences. <br /> <br />A recent concern is the integration of small captives with life insurance policies. Small captives, under Section 831(b), have no statutory authority to deduct life premiums. Also, if a small captive uses life insurance as an investment, the cash value of the life policy can be taxable at corporate rates, and then will be taxable again when distributed. The consequence of this double taxation is to devastate the effectiveness of the life insurance, and it extends serious liability to any accountant who recommends the plan or even signs the tax return of the business that pays premiums to the captive.<br /> <br />The IRS is aware that several large insurance companies are promoting their life insurance policies as investments with small captives. The outcome looks eerily like that of the 419 and 412(i) plans mentioned above. <br /> <br />Remember, if something looks too good to be true, it usually is. There are safe and conservative ways to use captive insurance structures to lower costs and obtain benefits for businesses. And, some types of captive insurance products do have statutory protection for deducting life insurance premiums (although not 831(b) captives). Learning what works and is safe is the first step an accountant should take in helping his or her clients use these powerful, but highly technical insurance tools. <br /><br /><br /><br />Lance Wallach, the National Society of Accountants Speaker of the Year, speaks and writes extensively about retirement plans, Circular 230 problems and tax reduction strategies. He speaks at more than 40 conventions annually, writes for over 50 publications and has written numerous best-selling AICPA books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Business Hot Spots. Contact him at 516.938.5007 or visit www.vebaplan.com.<br /><br />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.<br />Lance Wallachhttps://www.blogger.com/profile/05541601942749133861noreply@blogger.comtag:blogger.com,1999:blog-4462792519972887259.post-70869783932654821142014-04-17T14:13:47.592-04:002014-04-17T14:13:47.592-04:00Post a Comment On: Captive Insurance & 419 Pla...Post a Comment On: Captive Insurance & 419 Plans Litigation<br /><br />"Captive Insurance"<br />2 Comments - Show Original Post<br />Collapse comments<br />1 – 2 of 2<br />Blogger Lance Wallach said...<br />HomeAboutServicesBlogVideosBooksArticlesContact<br />IRS Audits Focus on Captive Insurance Plans<br />18 August 2011<br />Guest Post by Lance Wallach<br /><br />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.<br /><br />Insurance agents, financial plannelance wallachhttps://www.blogger.com/profile/05381002998730283542noreply@blogger.comtag:blogger.com,1999:blog-4462792519972887259.post-83720170513723355092014-04-08T09:31:16.884-04:002014-04-08T09:31:16.884-04:00HOME PAGE
IRS ATTACKS BENEFIT PLAN
TAX REDUCTION S...HOME PAGE<br />IRS ATTACKS BENEFIT PLAN<br />TAX REDUCTION STRATEGIES<br />VEBA PLANS<br />INSURANCE AND ANNUITIES<br />CAPTIVE INSURANCE<br />IRS AUDIT ASSISTANCE<br />STOCK MARKET AND LOSSES<br />EXPERT WITNESS<br />INFORMATIONAL LINKS<br />Lance Wallach Should Be Your Expert Witness<br />TaxLibrary.us<br />5 1 6 - 9 3 8 - 5 0 0 7 <br />Nationwide Assistance<br />WallachInc@gmail.com <br />See Our Detailed List of Services Below<br />Federal Court in Illinois Shuts Down Nationwide “Employee Benefit Plan” Tax Scheme<br /><br /><br />Department of Justice<br /><br />Office of Public Affairs<br />FOR IMMEDIATE RELEASE<br /><br />Tuesday, March 6, 2012<br /><br />A federal court has permanently barred Tracy L. Sunderlage, Linda Sunderlage and four companies from operating an alleged scheme to help high-income individuals attempt to avoid income taxes by funneling money through purported employee benefit plans, the Justice Department announced today. Judge John W. Darrah of the U.S. District Court for the Northern District of Illinois entered the permanent injunction orders, to which the defendants consented, against the Sunderlages, SRG International Ltd., of Nevis, West Indies, and three Illinois companies - SRG International U.S. LLC, Maven U.S. LLC and Randall Administration LLC.<br /><br />To Read More Click Link Below:<br />http://gettracysunderlagehelp.blogspot.com/<br /><br /><br /><br /><br /><br />Massachusetts Society of Certified Public Accounts, Inc.<br />Winter 2010<br />IRS Attacks Business Owners in 419, 412, Section 79 and Captive Insurance Plans Under Section 6707A<br /><br /> SchemeLance Wallachhttps://www.blogger.com/profile/05541601942749133861noreply@blogger.comtag:blogger.com,1999:blog-4462792519972887259.post-53926778162963966282014-03-19T07:37:07.245-04:002014-03-19T07:37:07.245-04:00Lance Wallach Life Insurance
Thursday, February 2...Lance Wallach Life Insurance<br /><br />Thursday, February 27, 2014<br />Captive Insurance Buyer Beware<br /> Hg Experts <br /> Legal Experts Directory<br /><br /> <br />Captive Insurance Buyer Beware<br /> By Lance Wallach, CLU, CHFC Abusive Tax Shelter, Listed Transaction, Reportable Transaction Expert Witness<br /><br />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.<br /><br />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.<br /><br />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.<br /><br />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).<br /><br />Optimum utilization of a captive by a small business, medical practice, or professional.<br /><br />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.<br />lance wallachhttps://www.blogger.com/profile/05381002998730283542noreply@blogger.com