412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.
412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.
ReplyDeleteVeba Health Care
SUNDAY, DECEMBER 1, 2013
IRS to Audit Sea Nine VEBA Participating Employers. Lance Wallach, expert witness.
The IRS may be auditing many more participating employers in the coming months.
In recent months, I have received phone calls from participants in the Sea Nine VEBA and have learned that the IRS may be auditing many more participating employers in the coming months. To better assist current Sea Nine clients and those that are now or may be under audit in the future, my associates who are CPAs, tax attys and former IRS employees will continue to help with the Sea Nine VEBA victims and others in 419 412i captive insurance and section 79 scams and answer the following:
• What is the IRS’s position with respect to the Sea Nine VEBA,419 captive insurance and section 79 scams?
• What will be the likely result of my audit?
• What if I don't agree with my audit results?
• What are other participants doing with respect to the audits?
• Will the IRS impose interest and penalties?
• What is a “listed transaction” ?
• What is Form 8886, and what are the penalties for failing to file Form 8886?
• Will I be responsible even if I relied on my tax advisor?
• What recourse do I have against those that promoted and sold the Sea Nine VEBA?
As an expert witness Lance Wallach's side has never lost a case. People need to be careful of 419 Welfare Benefit Plans, 412i plans, Section 79 plans and Captive Insurance Plans. Most of these plans are sold by insurance agents. If you are in an abusive, listed or similar transaction plan you need to file under IRS 6707a. The participant files form 8886, and the salesmen or accountant who signs the tax returns files form 8918 if they got paid over $10,000. They are called Material Advisors and face a minimum $100,000 fine. Some plans are offshore which could involve FBAR or OVDI filings. If you have money overseas you probably need to file for IRS tax amnesty. If you want to reduce the tax we suggest that you first file and then opt out. For more information Google Lance Wallach.
Disclaimer: While every effort has been made to ensure the accuracy of this publication, it is not intended to provide legal advice as individual situations will differ and should be discussed with an expert and/or lawyer. For specific technical or legal advice on the information provided and related topics, please contact the author.