FBAR - Foreign Bank Account Reporting - The IRS is assessing huge penalties for undisclosed foreign bank accounts, assets and income.
FBAR FILING DEADLING HAS BEEN
EXTENDED
Big Trouble Ahead For 412i and 419 Plan Participants - Lance Wallach
We have knowledge of many different welfare benefit plans and experience in representing taxpayers who participate in those plans before the IRS. A sampling of the plans that we know well include:
Millennium Plan Insured Security Plan Corporate Benefit Services Plan Sea Nine Associates VEBA Niche National Benefit Plans Professional Benefit Trust (PBT) Koresko STEP Plan Bisys Plan Xelan Plan Sterling Plan
Question. What is the IRS position on these plans?
Answer. The IRS position appears to be that all multiple employer welfare benefit plans funded with permanent life insurance are abusive tax scams. Their history is to open promoter audits on every such plan and eventually to obtain the client lists from the promoters and then audit their clients. The IRS position on single employer welfare benefit plans that are spin-offs of the multiple employer plans appears to be the same. Similarly, the IRS position on single employer welfare benefit plans invested in permanent life insurance where the employer deducts more than the term cost of insurance is that those plans are also abusive tax scams.
Question. Has the IRS approved any multiple or single employer welfare benefit plan invested in permanent life insurance?
Answer. Though an IRS private letter ruling is not immediately public, it is my understanding that the IRS has never “approved” of any multiple or single employer welfare benefit plan where permanent life insurance was used as a funding vehicle and the participating employer took a deduction for anything other than the current term insurance cost.
We have knowledge of many different welfare benefit plans and experience in representing taxpayers who participate in those plans before the IRS. A sampling of the plans that we know well include:
ReplyDeleteMillennium Plan
Insured Security Plan
Corporate Benefit Services Plan
Sea Nine Associates VEBA
Niche National Benefit Plans
Professional Benefit Trust (PBT)
Koresko STEP Plan
Bisys Plan
Xelan Plan
Sterling Plan
Question. What is the IRS position on these plans?
Answer. The IRS position appears to be that all multiple employer welfare benefit plans funded with permanent life insurance are abusive tax scams. Their history is to open promoter audits on every such plan and eventually to obtain the client lists from the promoters and then audit their clients. The IRS position on single employer welfare benefit plans that are spin-offs of the multiple employer plans appears to be the same. Similarly, the IRS position on single employer welfare benefit plans invested in permanent life insurance where the employer deducts more than the term cost of insurance is that those plans are also abusive tax scams.
Question. Has the IRS approved any multiple or single employer welfare benefit plan invested in permanent life insurance?
Answer. Though an IRS private letter ruling is not immediately public, it is my understanding that the IRS has never “approved” of any multiple or single employer welfare benefit plan where permanent life insurance was used as a funding vehicle and the participating employer took a deduction for anything other than the current term insurance cost.