Lance's Blog | The expert on IRS audits of 419e and 412i plans, 6707A, listed and reportable transactions,Section 79, captive insurance and abusive tax shelters

Lance's Blog | The expert on IRS audits of 419e and 412i plans, 6707A, listed and reportable transactions,Section 79, captive insurance and abusive tax shelters

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  1. Be careful of abusive 419(e) welfare benefit plans
    MARCH 24, 2015
    Originally posted on 419.Tax:

    accounting-today-logo BY LANCE WALLACH AND RONALD H. SNYDER

    Life insurance agents and companies have always tried to find ways of making costs paid by business owners tax deductible.

    The situation became ridiculous a few years ago with outrageous claims about how Sections 419A(f)(5) and (6) of the Internal Revenue Code exempted employers from any tax-deduction limitations. Finally, the Internal Revenue Service put a stop to such egregious misrepresentations in 2002 by issuing regulations and naming such plans as “potentially abusive tax shelters” (or “listed transactions”) that needed to be registered and disclosed to the IRS.

    And what happened to the providers that were peddling Sections 419A(f)(5) and (6) life insurance plans a few years ago? We recently found the answer: Most of them found a new life as promoters of so-called “419(e)” welfare benefit plans.

    IRC Section 419(e) provides a definition of the term “welfare benefit fund” and provides that it…

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