MuniBond Life Insurance 412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.
IRS to Audit Sea Nine VEBA Participating Employers
December 20, 2012 By Lance Wallach, CLU, CHFC
IRS audit of Sea Nine participating employers By Lance Wallach
IRS audit of Sea Nine participating employers In recent months, I have received phone calls from participants in the Sea Nine VEBA and have learned that the IRS may be auditing many more participating employers in the coming months. To better assist current Sea Nine clients and those that are now or may be under audit in the future, my associates who are CPAs, tax attys and former IRS employees will continue to help with the Sea Nine VEBA victims and others in 419 412i captive insurance and section 79 scams and answer the following:
• What is the IRS’s position with respect to the Sea Nine VEBA,419 captive insurance and section 79 scams?
• What will be the likely result of my audit?• What are other participants doing with respect to the audits?
• 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?
ABOUT THE AUTHOR: Lance Wallach 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, abusive tax shelters, international tax, and other subjects. He writes about FBAR,OVDI, international taxation, captive insurance plans and other topics. He speaks at more than ten conventions annually, writes for over fifty 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 the AICPA best-selling books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots.
Copyright Lance Wallach, CLU, CHFC - Google+ More information about Lance Wallach, CLU, CHFC
Disclaimer: 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. Posted by Lance Wallach at 7/15/2015 03:25:00 PM Labels: 412i Benefit Plan, 419, abusive tax shelters, expert witness, IRS Audits, Sea Nine Veba 60 comments:
Lance WallachSeptember 13, 2013 at 12:01 PM Failing to File Form 8886 for VEBAs like Sea Nine VEBA create multiple penalties.
Taxpayers who participate in 419A(f)(6) multiple employer plans like the Sea Nine VEBA are often very discouraged to find the IRS applying multiple penalties for the failure to file a form that they had no reason to know was required. The form, IRS Form 8886 is required for all taxpayers who participate in a listed transaction such as a multiple employer welfare benefit plan (or 419 plan). The following example illustrates the penalties that can apply.
Assume we have an S corporation taxpayer who deducted $100,000 to a multiple employer 419 VEBA for years 2008, 2009 and 2010. The IRS audits the taxpayer and disallows the $100,000 deduction. In most cases, the IRS will provide for the adjustment at the individual 1040 level and other than some interest, the taxpayer will be in a position similar to if the transaction had not occurred. If, however, the taxpayer was not told to file Form 8886 for every year of participation and in
ReplyDeleteMuniBond Life Insurance
412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.
IRS to Audit Sea Nine VEBA Participating Employers
December 20, 2012 By Lance Wallach, CLU, CHFC
IRS audit of Sea Nine participating employers
By Lance Wallach
IRS audit of Sea Nine participating employers
In recent months, I have received phone calls from participants in the Sea Nine VEBA and have learned that the IRS may be auditing many more participating employers in the coming months. To better assist current Sea Nine clients and those that are now or may be under audit in the future, my associates who are CPAs, tax attys and former IRS employees will continue to help with the Sea Nine VEBA victims and others in 419 412i captive insurance and section 79 scams and answer the following:
• What is the IRS’s position with respect to the Sea Nine VEBA,419 captive insurance and section 79 scams?
• What will be the likely result of my audit?• What are other participants doing with respect to the audits?
• 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?
ABOUT THE AUTHOR: Lance Wallach
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, abusive tax shelters, international tax, and other subjects. He writes about FBAR,OVDI, international taxation, captive insurance plans and other topics. He speaks at more than ten conventions annually, writes for over fifty 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 the AICPA best-selling books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots.
Copyright Lance Wallach, CLU, CHFC - Google+
More information about Lance Wallach, CLU, CHFC
Disclaimer: 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.
Posted by Lance Wallach at 7/15/2015 03:25:00 PM
Labels: 412i Benefit Plan, 419, abusive tax shelters, expert witness, IRS Audits, Sea Nine Veba
60 comments:
Lance WallachSeptember 13, 2013 at 12:01 PM
Failing to File Form 8886 for VEBAs like Sea Nine VEBA create multiple penalties.
Taxpayers who participate in 419A(f)(6) multiple employer plans like the Sea Nine VEBA are often very discouraged to find the IRS applying multiple penalties for the failure to file a form that they had no reason to know was required. The form, IRS Form 8886 is required for all taxpayers who participate in a listed transaction such as a multiple employer welfare benefit plan (or 419 plan). The following example illustrates the penalties that can apply.
Assume we have an S corporation taxpayer who deducted $100,000 to a multiple employer 419 VEBA for years 2008, 2009 and 2010. The IRS audits the taxpayer and disallows the $100,000 deduction. In most cases, the IRS will provide for the adjustment at the individual 1040 level and other than some interest, the taxpayer will be in a position similar to if the transaction had not occurred. If, however, the taxpayer was not told to file Form 8886 for every year of participation and in