Showing posts with label IRS Audits. Show all posts
Showing posts with label IRS Audits. Show all posts
Lance Wallach, Section 79 Problems, IRS, 419, 412i
Lance Wallach, Section 79 Problems, IRS, 419, 412i: Lance Wallach, Expert Witness, Section 79 plans, Section 79 Problems, Section 79, IRS, Tax, Lance Wallach Expert Witness, Audits, 419 412i, expert witness services
Abusive Insurance and Retirement Plans
Many of the listed transactions that can get your clients into trouble with the IRS are exotic shelters that relatively few practitioners ever encounter. When was the last time you saw someone file a return as a Guamanian trust (Notice 2000-61)? On the other hand, a few listed transactions concern relatively common employee benefit plans the IRS has deemed tax-avoidance schemes or otherwise abusive. Perhaps some of the most likely to crop up, especially in small business returns, are arrangements purporting to allow deductibility of premiums paid for life insurance under a welfare benefit plan.
Some of these abusive employee benefit plans are represented as satisfying section 419 of the Code, which sets limits on purposes and balances of “qualified asset accounts” for such benefits, but purport to offer deductibility of contributions without any corresponding income.
FBAR/OVDI LANCE WALLACH: 419 412i plans IRS audits lawsuits | LinkedIn
FBAR/OVDI LANCE WALLACH: 419 412i plans IRS audits lawsuits | LinkedIn: 419 412i plans IRS audits lawsuits | LinkedIn
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