Lance Wallach, CLU, ChFC, CIMC, the National Society of Accountants Speaker of the Year, consults on abusive tax shelters, captive insurance, conservation easements,bitcoin, ,insurance, estate planning, retirement and employee benefit plans,419,412i,section 79 plans and other IRS audit targets etc. As an expert witness his side has never lost a case. Lance Wallach advised thousands of high-income clients including hundreds of famous entertainers and athletes about captive insurance, 419, 412i section 79 and other abusive tax shelters. Lance also counseled famous Wall Street luminaries such as Hugh Downs and Louis Rukeyser, the host of 2 long-running programs Wall Street Week with Louis Rukeyser & Louis Rukeyser’s Wall Street. Speaker at over 50 annual conventions and author for more than 500 publications on tax reduction ideas, abusive welfare benefit and retirement plans, captive insurance companies,abusive tax shelters and conservation easements, cash balance plans, life settlements, premium finance, and more. He is a course developer and instructor for Continuing Professional Education courses administered by The American Institute of Certified Public Accountants. Lance is a prolific author, having written or collaborated on numerous books, including 'The CPA Guide to Life Insurance', published by BISK Education, 'The Team Approach to Tax and Financial Planning', published by the American Institute of CPA s, and most recently 'Protecting Clients from Fraud, Incompetence, and Scams', published by Wiley. He has been hired as an expert witness on some issues of which he speaks about, and to this day, Lance Wallach has never lost a case. Lance Wallach has appeared on radio and TV financial programs, most recently, on National Public Radio and NBC 25. Lance consults on abusive tax shelters like 412i,419, section 79, captive insurance bitcoin, easements, tax shelters and VEBA Plans. Additionally, Lance Wallach's expertise is sought after by the U.S. Securities and Exchange Commission, U.S. Department of Labor, the Enforcement Unit of the IRS The State Inusrance Dept etc.
Previously the realm of large corporations, a growing number of mid-sized and small businesses, professional service companies, and nonprofit organizations have been taking advantage of domestic and offshore captive insurance arrangements.
Although the establishment and management of a captive insurance company (“captive”) is legal, some have come under IRS scrutiny.
Benefits of captive insurance Captive insurance is a kind of self-insurance company formed to provide coverage for a wide variety of business property and casualty risks. Premiums are not paid to an outside insurance company, but are instead invested and accumulate over time. The funds can later be used to cover losses connected to business risks that are either uninsurable or for which commercial insurance coverage is unreasonably priced.
In addition to the primary benefits related to cash flow and risk management, if a captive has the required economic and business purpose its premiums provide significant tax, estate planning and asset protection benefits. Captives can also provide a company with access to the reinsurance market, which can also provide significant cost savings and an opportunity to make additional profits from insurance sales.
Types of captive insurance Captives take many forms, including pure (single parent), association (group), agency, alien, branch, diversified, reciprocal (risk retention groups), microcaptives, rent-a-captives and special purpose vehicles/reinsurers.
Previously the realm of large corporations, a growing number of mid-sized and small businesses, professional service companies, and nonprofit organizations have been taking advantage of domestic and offshore captive insurance arrangements.
Although the establishment and management of a captive insurance company (“captive”) is legal, some have come under IRS scrutiny.
Benefits of captive insurance Captive insurance is a kind of self-insurance company formed to provide coverage for a wide variety of business property and casualty risks. Premiums are not paid to an outside insurance company, but are instead invested and accumulate over time. The funds can later be used to cover losses connected to business risks that are either uninsurable or for which commercial insurance coverage is unreasonably priced.
In addition to the primary benefits related to cash flow and risk management, if a captive has the required economic and business purpose its premiums provide significant tax, estate planning and asset protection benefits. Captives can also provide a company with access to the reinsurance market, which can also provide significant cost savings and an opportunity to make additional profits from insurance sales.
Types of captive insurance Captives take many forms, including pure (single parent), association (group), agency, alien, branch, diversified, reciprocal (risk retention groups), microcaptives, rent-a-captives and special purpose vehicles/reinsurers.
Previously the realm of large corporations, a growing number of mid-sized and small businesses, professional service companies, and nonprofit organizations have been taking advantage of domestic and offshore captive insurance arrangements.
Although the establishment and management of a captive insurance company (“captive”) is legal, some have come under IRS scrutiny.
Benefits of captive insurance Captive insurance is a kind of self-insurance company formed to provide coverage for a wide variety of business property and casualty risks. Premiums are not paid to an outside insurance company, but are instead invested and accumulate over time. The funds can later be used to cover losses connected to business risks that are either uninsurable or for which commercial insurance coverage is unreasonably priced.
In addition to the primary benefits related to cash flow and risk management, if a captive has the required economic and business purpose its premiums provide significant tax, estate planning and asset protection benefits. Captives can also provide a company with access to the reinsurance market, which can also provide significant cost savings and an opportunity to make additional profits from insurance sales.
Types of captive insurance Captives take many forms, including pure (single parent), association (group), agency, alien, branch, diversified, reciprocal (risk retention groups), microcaptives, rent-a-captives and special purpose vehicles/reinsurers.
The Internal Revenue Service announced today the mailing of a time-limited settlement offer for certain taxpayers under audit who participated in abusive micro-captive insurance transactions.
Taxpayers eligible for this offer will be notified by letter with the applicable terms. Taxpayers who do not receive such a letter are not eligible for this resolution.
Abusive micro-captives have been a concern to the IRS for several years. The transactions have appeared on the IRS "Dirty Dozen" list of tax scams since 2014. In 2016, the Department of Treasury and IRS issued Notice 2016-66 (PDF), which identified certain micro-captive transactions as having the potential for tax avoidance and evasion.
Following wins in three recent U.S. Tax Court cases, the IRS has decided to offer settlements to taxpayers currently under exam. In recent days, the IRS started sending notices to up to 200 taxpayers.
Tax law generally allows businesses to create "captive" insurance companies to protect against certain risks. Under section 831(b) of the Internal Revenue Code, certain small insurance companies can choose to pay tax only on their investment income. In abusive "micro-captive" structures, promoters, accountants or wealth planners persuade owners of closely held entities to participate in schemes that lack many of the attributes of genuine insurance.
The IRS has consistently disallowed the tax benefits claimed by taxpayers in abusive micro-captive structures. Although some taxpayers have challenged the IRS position in court, none have been successful. To the contrary, the Tax Court has now sustained the IRS' disallowance of the claimed tax benefits in three different cases.
The IRS will continue to disallow the tax benefits claimed in these abusive transactions and will continue to defend its position in court. The IRS has decided, however, to offer to resolve certain of these cases on the terms outlined below.
"The IRS is taking this step in the interests of sound tax administration," IRS Commissioner Chuck Rettig said. "We encourage taxpayers under exam and their advisors to take a realistic look at their matter and carefully review the settlement
For those wishing to protect their captive, we’ll get you compliant. And for those facing an audit, we’ll be your defense.
Businesses have been creating captive insurance companies (CICs) for more than 100 years in order to manage risk while taking advantage of the tax benefits offered by the insurance arrangement.
However, the IRS has started to evaluate possible abuses surrounding CICs, and has begun examinations in the area. For those businesses who are unprepared when facing examination, there can be consequences.
alliantNational leverages its years of experience with protecting taxpayers to help its clients navigate the complex world of captive insurance compliance, with its team of former high-ranking IRS executives, key congressional personnel and experienced litigators ensuring that each client has the strongest defense possible in the event of an audit.
Lance Wallach, CLU, ChFC, CIMC, the National Society of Accountants Speaker of the Year, consults on abusive tax shelters, captive insurance, conservation easements,bitcoin, ,insurance, estate planning, retirement and employee benefit plans,419,412i,section 79 plans and other IRS audit targets etc. As an expert witness his side has never lost a case.
ReplyDeleteLance Wallach advised thousands of high-income clients including hundreds of famous entertainers and athletes about captive insurance, 419, 412i section 79 and other abusive tax shelters. Lance also counseled famous Wall Street luminaries such as Hugh Downs and Louis Rukeyser, the host of 2 long-running programs Wall Street Week with Louis Rukeyser & Louis Rukeyser’s Wall Street.
Speaker at over 50 annual conventions and author for more than 500 publications on tax reduction ideas, abusive welfare benefit and retirement plans, captive insurance companies,abusive tax shelters and conservation easements, cash balance plans, life settlements, premium finance, and more. He is a course developer and instructor for Continuing Professional Education courses administered by
The American Institute of Certified Public Accountants.
Lance is a prolific author, having written or collaborated on numerous books, including 'The CPA Guide to Life Insurance', published by BISK Education, 'The Team Approach to Tax and Financial Planning', published by the American Institute of CPA s, and most recently 'Protecting Clients from Fraud, Incompetence, and Scams', published by Wiley. He has been hired as an expert witness on some issues of which he speaks about, and to this day, Lance Wallach has never lost a case.
Lance Wallach has appeared on radio and TV financial programs, most recently, on National Public Radio and NBC 25. Lance consults on abusive tax shelters like 412i,419, section 79, captive insurance bitcoin, easements, tax shelters and VEBA Plans.
Additionally, Lance Wallach's expertise is sought after by the U.S. Securities and Exchange Commission, U.S. Department of Labor, the Enforcement Unit of the IRS The State Inusrance Dept etc.
Previously the realm of large corporations, a growing number of mid-sized and small businesses, professional service companies, and nonprofit organizations have been taking advantage of domestic and offshore captive insurance arrangements.
ReplyDeleteAlthough the establishment and management of a captive insurance company (“captive”) is legal, some have come under IRS scrutiny.
Benefits of captive insurance
Captive insurance is a kind of self-insurance company formed to provide coverage for a wide variety of business property and casualty risks. Premiums are not paid to an outside insurance company, but are instead invested and accumulate over time. The funds can later be used to cover losses connected to business risks that are either uninsurable or for which commercial insurance coverage is unreasonably priced.
In addition to the primary benefits related to cash flow and risk management, if a captive has the required economic and business purpose its premiums provide significant tax, estate planning and asset protection benefits. Captives can also provide a company with access to the reinsurance market, which can also provide significant cost savings and an opportunity to make additional profits from insurance sales.
Types of captive insurance
Captives take many forms, including pure (single parent), association (group), agency, alien, branch, diversified, reciprocal (risk retention groups), microcaptives, rent-a-captives and special purpose vehicles/reinsurers.
Previously the realm of large corporations, a growing number of mid-sized and small businesses, professional service companies, and nonprofit organizations have been taking advantage of domestic and offshore captive insurance arrangements.
ReplyDeleteAlthough the establishment and management of a captive insurance company (“captive”) is legal, some have come under IRS scrutiny.
Benefits of captive insurance
Captive insurance is a kind of self-insurance company formed to provide coverage for a wide variety of business property and casualty risks. Premiums are not paid to an outside insurance company, but are instead invested and accumulate over time. The funds can later be used to cover losses connected to business risks that are either uninsurable or for which commercial insurance coverage is unreasonably priced.
In addition to the primary benefits related to cash flow and risk management, if a captive has the required economic and business purpose its premiums provide significant tax, estate planning and asset protection benefits. Captives can also provide a company with access to the reinsurance market, which can also provide significant cost savings and an opportunity to make additional profits from insurance sales.
Types of captive insurance
Captives take many forms, including pure (single parent), association (group), agency, alien, branch, diversified, reciprocal (risk retention groups), microcaptives, rent-a-captives and special purpose vehicles/reinsurers.
Previously the realm of large corporations, a growing number of mid-sized and small businesses, professional service companies, and nonprofit organizations have been taking advantage of domestic and offshore captive insurance arrangements.
ReplyDeleteAlthough the establishment and management of a captive insurance company (“captive”) is legal, some have come under IRS scrutiny.
Benefits of captive insurance
Captive insurance is a kind of self-insurance company formed to provide coverage for a wide variety of business property and casualty risks. Premiums are not paid to an outside insurance company, but are instead invested and accumulate over time. The funds can later be used to cover losses connected to business risks that are either uninsurable or for which commercial insurance coverage is unreasonably priced.
In addition to the primary benefits related to cash flow and risk management, if a captive has the required economic and business purpose its premiums provide significant tax, estate planning and asset protection benefits. Captives can also provide a company with access to the reinsurance market, which can also provide significant cost savings and an opportunity to make additional profits from insurance sales.
Types of captive insurance
Captives take many forms, including pure (single parent), association (group), agency, alien, branch, diversified, reciprocal (risk retention groups), microcaptives, rent-a-captives and special purpose vehicles/reinsurers.
The Internal Revenue Service announced today the mailing of a time-limited settlement offer for certain taxpayers under audit who participated in abusive micro-captive insurance transactions.
ReplyDeleteTaxpayers eligible for this offer will be notified by letter with the applicable terms. Taxpayers who do not receive such a letter are not eligible for this resolution.
Abusive micro-captives have been a concern to the IRS for several years. The transactions have appeared on the IRS "Dirty Dozen" list of tax scams since 2014. In 2016, the Department of Treasury and IRS issued Notice 2016-66 (PDF), which identified certain micro-captive transactions as having the potential for tax avoidance and evasion.
Following wins in three recent U.S. Tax Court cases, the IRS has decided to offer settlements to taxpayers currently under exam. In recent days, the IRS started sending notices to up to 200 taxpayers.
Tax law generally allows businesses to create "captive" insurance companies to protect against certain risks. Under section 831(b) of the Internal Revenue Code, certain small insurance companies can choose to pay tax only on their investment income. In abusive "micro-captive" structures, promoters, accountants or wealth planners persuade owners of closely held entities to participate in schemes that lack many of the attributes of genuine insurance.
The IRS has consistently disallowed the tax benefits claimed by taxpayers in abusive micro-captive structures. Although some taxpayers have challenged the IRS position in court, none have been successful. To the contrary, the Tax Court has now sustained the IRS' disallowance of the claimed tax benefits in three different cases.
The IRS will continue to disallow the tax benefits claimed in these abusive transactions and will continue to defend its position in court. The IRS has decided, however, to offer to resolve certain of these cases on the terms outlined below.
"The IRS is taking this step in the interests of sound tax administration," IRS Commissioner Chuck Rettig said. "We encourage taxpayers under exam and their advisors to take a realistic look at their matter and carefully review the settlement
For those wishing to protect their captive, we’ll get you compliant.
ReplyDeleteAnd for those facing an audit, we’ll be your defense.
Businesses have been creating captive insurance companies (CICs) for more than 100 years in order to manage risk while taking advantage of the tax benefits offered by the insurance arrangement.
However, the IRS has started to evaluate possible abuses surrounding CICs, and has begun examinations in the area. For those businesses who are unprepared when facing examination, there can be consequences.
alliantNational leverages its years of experience with protecting taxpayers to help its clients navigate the complex world of captive insurance compliance, with its team of former high-ranking IRS executives, key congressional personnel and experienced litigators ensuring that each client has the strongest defense possible in the event of an audit.