IRS Auditing 412i, 419e


Plan Administrator Frustrated With IRS Attacks on 412i, 412e Plans

IRS Auditing 412(i) Plans


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  1. Diversity Market
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    FROM THE OCTOBER 01, 2010 ISSUE OF AGENT’S SALES JOURNAL • SUBSCRIBE!

    How to Avoid IRS Fines for You and Your Clients
    BY LANCE WALLACH
    OCTOBER 26, 2010 • REPRINTS
    Share on linkedin Share on twitter Share on facebook Share on email More Sharing Services
    28
    Beware: The IRS is cracking down on small-business owners who participate in tax-reduction insurance plans sold by insurance agents, including defined benefit retirement plans, IRAs, and even 401(k) plans with life insurance. In these cases, the business owner is motivated by a large tax deduction; the insuran

    ReplyDelete
  2. google lance wallach for help
    Material Advisors & 419 Plans Litigation
    412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.

    Friday, November 1, 2013

    Class Action Challenges Propriety of 412(e)(3) Annuities. Lance Wallach, expert witness.
    On August 1, 2012, a putative class action lawsuit was filed in the District of Connecticut challenging the propriety of certain insurance contracts used to fund defined benefit plans described in section 412(e)(3) of the Internal Revenue Code. U.S. Telemanagement, Inc. v. Fidelity Security Life Insurance Co. et al., No. 3:12-cv-1110 JBA (D. Conn.).

    Because we perceive that the complaint is attacking the appropriateness of the product, as well as the specifics of the product that the named defendant sold, it is a lawsuit that potentially could have industry-wide implications. In addition, as plaintiffs in some of the ERISA revenue-sharing lawsuits have attempted to do, the complaint alleges that the insurance company that sold the annuities acted as an ERISA fiduciary of the plans. This lawsuit thus extends the attack on insurance companies, as seen in the revenue-sharing class actions, that attempts to convert service providers into fiduciaries.

    412(e)(3) Plans and Annuities

    A 412(e)(3) plan is a tax-qualified, defined benefit pension plan that is funded with either annuities or a combination of annuities and life insurance. These sorts of plans are most often funded through annuities, and those annuities have come to be known as 412(e)(3) annuities, because of the section of the Internal Revenue Code that authorizes this sort of plan. Such 412(e)(3) plans are normally marketed to small businesses as vehicles that can provide large income tax deductions in connection with the establishment or continued funding of a pension plan. The annuities used to fund such a plan often are priced upon low assumed rates of return and other actuarial factors, which means that the employer is required to contribute a larger amount of money up front to fund the plan, and that in turn provides employers with larger tax deductions for their business

    ReplyDelete
  3. Material Advisors & 419 Plans Litigation
    412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.

    Tuesday, August 16, 2011

    IRS Auditing 412i, 419e

    Plan Administrator Frustrated With IRS Attacks on 412i, 412e Plans

    IRS Auditing 412(i) Plans

    ReplyDelete
  4. Material Advisors & 419 Plans Litigation
    412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.

    Tuesday, August 16, 2011

    IRS Auditing 412i, 419e

    Plan Administrator Frustrated With IRS Attacks on 412i, 412e Plans

    IRS Auditing 412(i) Plans www.taxaudit419.com for help

    ReplyDelete
  5. Tuesday, August 16, 2011

    IRS Auditing 412i, 419e

    Plan Administrator Frustrated With IRS Attacks on 412i, 412e Plans

    IRS Auditing 412(i) Plans



    Posted by Lance Wallach at 12:16 PM
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    Labels: Audits, IRS, IRS Audits, Lance Wallach, Lance Wallach Expert Witness
    4 comments:

    Lance WallachJanuary 22, 2014 at 6:20 AM
    Diversity Market
    Gen X & Y
    Company News
    Your Practice
    Magazines
    Resource Center

    FROM THE OCTOBER 01, 2010 ISSUE OF AGENT’S SALES JOURNAL • SUBSCRIBE!

    How to Avoid IRS Fines for You and Your Clients
    BY LANCE WALLACH
    OCTOBER 26, 2010 • REPRINTS
    Share on linkedin Share on twitter Share on facebook Share on email More Sharing Services
    28
    Beware: The IRS is cracking down on small-business owners who participate in tax-reduction insurance plans sold by insurance agents, including defined benefit retirement plans, IRAs, and even 401(k) plans with life insurance. In these cases, the business owner is motivated by a large tax deduction; the insuran

    ReplyDelete

    Lance WallachJanuary 24, 2014 at 1:06 PM
    google lance wallach for help
    Material Advisors & 419 Plans Litigation
    412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.

    Friday, November 1, 2013

    Class Action Challenges Propriety of 412(e)(3) Annuities. Lance Wallach, expert witness.
    On August 1, 2012, a putative class action lawsuit was filed in the District of Connecticut challenging the propriety of certain insurance contracts used to fund defined benefit plans described in section 412(e)(3) of the Internal Revenue Code. U.S. Telemanagement, Inc. v. Fidelity Security Life Insurance Co. et al., No. 3:12-cv-1110 JBA (D. Conn.).

    Because we perceive that the complaint is attacking the appropriateness of the product, as well as the specifics of the product that the named defendant sold, it is a lawsuit that potentially could have industry-wide implications. In addition, as plaintiffs in some of the ERISA revenue-sharing lawsuits have attempted to do, the complaint alleges that the insurance company that sold the annuities acted as an ERISA fiduciary of the plans. This lawsuit thus extends the attack on insurance companies, as seen in the revenue-sharing class actions, that attempts to convert service providers into fiduciaries.

    412(e)(3) Plans and Annuities

    A 412(e)(3) plan is a tax-qualified, defined benefit pension plan that is funded with either annuities or a combination of annuities and life insurance. These sorts of plans are most often funded through annuities, and those annuities have come to be known as 412(e)(3) annuities, because of the section of the Internal Revenue Code that authorizes this sort of plan. Such 412(e)(3) plans are normally marketed to small businesses as vehicles that can provide large income tax deductions in connection with the establishment or continued funding of a pension plan. The annuities used to fund such a plan often are priced upon low assumed rates of return and other actuarial factors, which means that the employer is required to contribute a larger amount of money up front to fund the plan, and that in turn provides employers with larger tax deductions for their business

    ReplyDelete

    Lance WallachJanuary 24, 2014 at 1:08 PM
    Material Advisors & 419 Plans Litigation
    412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.

    Tuesday, August 16, 2011

    IRS Auditing 412i, 419e

    Plan Administrator Frustrated With IRS Attacks on 412i, 412e Plans

    IRS Auditing 412(i) Plans

    ReplyDelete

    Lance WallachJanuary 24, 2014 at 1:10 PM
    Material Advisors & 419 Plans Litigation
    412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.

    Tuesday, August 16, 2011

    IRS Auditing 412i, 419e

    Plan Administrator Frustrated With IRS Attacks on 412i, 412e Plans

    IRS Auditing 412(i) Plans www.taxaudit419.com for help

    ReplyDelete

    ReplyDelete