Form 8886 and 419 Plans Litigation,
412i and 419e plans litigation, IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.
US Says Benefit Plan Scheme Costs Millions In Taxes - Law360 www.law360.com/articles/479910/us-says-benefit-plan-sch... Oct 11, 2013 ... The government said one audit of some 41 customers who participated in the plans ... The involvement of Sea Nine Associates Inc. — which sponsors the VEBA plans ... “The core purpose and effect of the participation in a Sea Nine VEBA plan is to provide ... Employment ... Internal Revenue Service · Track ... Lance Wallach - Google+ plus.google.com/103938929810143210738 IRS to Audit Sea Nine VEBA Participating Employers. Lance Wallach, expert witness. The IRS may be auditing many more participating employers in the coming ...
Wednesday, March 12, 2014 KENNETH ELLIOT: Sea Nine VEBA Important KENNETH ELLIOT: Sea Nine VEBA Important: As of August 23,2013, the IRS has closed audits of 12 Sea Nine VEBA plan-participating taxpayers who were referred to Sea Nine by Sarva. For...
eporting by U.S. Persons Holding Foreign Financia Contact Information Email : LanWalla@aol.com Phone : 516-938-5007 Address : Lance Wallach www.vebaplan.org www.TaxAudit419.com IRS Form 8938 FATCA requires any U.S. person holding foreign financial assets with an aggregate value exceeding $50,000 to report certain information about those assets on a new form (Form 8938) that must be attached to the taxpayer’s annual tax return. Reporting applies for assets held in taxable years beginning on or after January 1, 2011. Failure to report foreign financial assets on Form 8938 will result in a penalty of $10,000 (and a penalty up to $50,000 for continued failure after IRS notification). Further, underpayments of tax attributable to non-disclosed foreign financial assets will be subject to an additional substantial understatement penalty of 40 percent. Under FATCA, U.S. taxpayers holding financial assets outside the United States must report those assets to the IRS on a new form attached to their tax return. Penalties apply for failure to comply with this new reporting requirement. Reporting is required for assets held in taxable years beginning on or after January 1
inShare 5 INFORMATION: PRACTICE AREAS: Tax WEB SITE: http://www.vebaplan.org/ BIO: Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, abusive tax shelters, financial, international tax, and estate planning. He writes about 412(i), 419, Section79, FBAR, and captive insurance plans. He speaks at more than ten conventions annually, writes for over fifty publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Pubic Radio’s All Things considered, and others. Lance has written numerous books including Protecting Clients from Fraud, incompetence and Scams published by John Wiley and Sons, Bisk Education’s CPA’s Guide to Life Insurance and Federal Estate and Gift Taxation, as well as the AICPA best-selling books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots. He does expert witness testimony and has never lost a case. Contact him at 516.938.5007, lawallach@aol.com or visit www.vebaplan.com.
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Indian Business Man Prosecuted For Unreported HSBC India Account Posted on February 24, 2014 by Brian M
Although all the media attention on unreported foreign accounts appears to focused on Switzerland, the Justice Department and IRS continue to look worldwide for U.S. taxpayers with undeclared offshore accounts. According to a press release from the United States Attorney’s Office, Sameer Gupta pleaded guilty last week to one count of tax evasion after the IRS discovered he had an unreported bank account at HSBC India. He faces 5 years in prison. Possessing or having signature authority over an account in India is entirely legal if the account is reported annually to the IRS. Foreign bank and investment accounts must be reported each year on a Report of Foreign Bank and Financial Accounts, also known as an FBAR or form TD 90-22.1. Failure to file an FBAR is a felony. Prosecutors say that in an effort to conceal his identity, Gupta had some 17 different bank accounts, several in nominee format. Opening an account in a false name or deliberately concealing one’s identity by opening an account in a third party name is considered an affirmative act of tax evasion. Prosecutors say the tax loss caused by Gupta’s activities was somewhere between $200,000 and $400,000. As part of his plea deal, Gupta agreed to pay the IRS a $259,000 penalty. The judge can impose
. Reporting by U.S. Persons Holding Foreign Financia Contact Information Email : LanWalla@aol.com Phone : 516-938-5007 Address : Lance Wallach www.vebaplan.org www.TaxAudit419.com IRS Form 8938 FATCA requires any U.S. person holding foreign financial assets with an aggregate value exceeding $50,000 to report certain information about those assets on a new form (Form 8938) that must be attached to the taxpayer’s annual tax return. Reporting applies for assets held in taxable years beginning on or after January 1, 2011. Failure to report foreign financial assets on Form 8938 will result in a penalty of $10,000 (and a penalty up to $50,000 for continued failure after IRS notification). Further, underpayments of tax attributable to non-disclosed foreign financial assets will be subject to an additional substantial understatement penalty of 40 percent. Under FATCA, U.S. taxpayers holding financial assets outside the United States must report those assets to the IRS on a new form attached to their tax return. Penalties apply for failure to comply with this new reporting requirement. Reporting is required for assets held in taxable years beginning on or after January 1
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FBAR OVDI Cause Americans Problems Over IRS Reporting Requirements By Lance Wallach, CLU, CHFC
The complexity of life insurance puts many litigators at a disadvantage when disputes reach the stage of legal action. In addition, if policies are part of a retirement plan or other tax-favored entity, special rules apply. Even the methods of paying for life insurance—especially split-dollar and outside premium financing—affect an outcome. Tax implications are another factor.
Lance Wallach is one of few professionals who know how the pieces work both alone and with estate and financial planning. In many situations, what the client bought or the way that they bought it was inappropriate. In other cases the right product was sold in the right way but the purchaser is unhappy. Richard has the forensic ability to uncover what has taken place.
Working for both plaintiffs and defendants, depending on the merits of the case, Lance advises, opines, and testifies based upon the facts, his knowledge and experience. This makes him a very powerful and credible witness.
On September 2, 2011, the IRS issued final regulations concerning the section 6707A penalty. Such a penalty is imposed on taxpayers who fail to include any information regarding a reportable transaction which was required to be disclosed. The final regulations follow the statutory language of section 6707A as amended by the Small Business Jobs Act of 2010, but do not give further guidance regarding the Service’s computation of the penalty.
It is anticipated that such penalty computation guidance will be issued at a later date.(such guidance is expected by way of regulations that will be issued at a later date). Nonetheless, the final regulations do provide additional guidance concerning rescission of the penalty.
The attorneys of Williams Coulson regularly represent clients with section 6707A matters before the Internal Revenue Service. Please do not hesitate to contact
The complexity of life insurance puts many litigators at a disadvantage when disputes reach the stage of legal action. In addition, if policies are part of a retirement plan or other tax-favored entity, special rules apply. Even the methods of paying for life insurance—especially split-dollar and outside premium financing—affect an outcome. Tax implications are another factor.
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EVENTS Find Legal Articles SEARCH Law Articles Recent Articles Articles by Location Articles by HG.org Expert Witnesses BackRecent ArticlesSubmit an Article RSS FEED Share: PRINT SHARE ON FACEBOOK SHARE ON TWITTER SHARE ON LINKEDIN SHARE ON GOOGLE+ Can You Recover Money from 419 and 412i Plans? By Lance Wallach, CLU, CHFC
Welfare Benefit Plan Fraud: What Remedies Are Available? If you’ve been the victim of a 419 Welfare Benefit Plan scheme and now find yourself owing the Internal Revenue Service (IRS) taxes on something you were told was going to be tax deductible, it’s important to know what remedies might be available to you.
Remedies for abusive tax shelter schemes Lance Wallach says that there are remedies for those who have been injured by an insurance company’s abusive tax shelter schemes. He predicts that we’ll see a huge spike in the number of people getting audited by the IRS.
Mediating 412(i) & 419 Claims: Can You Really Win? You can win. However, to do so successfully, a mediator should have the proper background and team– a powerful combination that is sometimes hard to come by. Having worked in almost every part of the life insurance industry for many years, Lance Wallach Is the Expert on tax shelter schemes involving Internal Revenue Code Sections 412(i) Pension Plans and Internal Revenue Code Section 419 Welfare Benefit Plans. Unwinding abusive insurance transactions There are not many firms who do what he does. 412(i) and 419 plans are generated by the insurance industry. So you’ve got to have knowledge about life insurance and the insurance industry first and foremost to understand the appeal of these transactions. Consequently, that’s why Lance Wallach gets contacted from people all over the country that are at one stage or another in these plans who are trying to get out, get their tax issues taken care of and get their money paid back. He is an expert witness on different ongoing cases –and has never lost a case. Working in conjunction with attorneys Our firm will review your case and make an assessment on it for free. When clients hire him they get all the experts at one firm that know the landscape of both 412(1) and 419 plans, and all work tog
US Says Benefit Plan Scheme Costs Millions In Taxes - Law360
ReplyDeletewww.law360.com/articles/479910/us-says-benefit-plan-sch...
Oct 11, 2013 ... The government said one audit of some 41 customers who participated in the plans ... The involvement of Sea Nine Associates Inc. — which sponsors the VEBA plans ... “The core purpose and effect of the participation in a Sea Nine VEBA plan is to provide ... Employment ... Internal Revenue Service · Track ...
Lance Wallach - Google+
plus.google.com/103938929810143210738
IRS to Audit Sea Nine VEBA Participating Employers. Lance Wallach, expert witness. The IRS may be auditing many more participating employers in the coming ...
Wednesday, March 12, 2014
ReplyDeleteKENNETH ELLIOT: Sea Nine VEBA Important
KENNETH ELLIOT: Sea Nine VEBA Important: As of August 23,2013, the IRS has closed audits of 12 Sea Nine VEBA plan-participating taxpayers who were referred to Sea Nine by Sarva. For...
eporting by U.S. Persons Holding Foreign Financia
ReplyDeleteContact Information
Email :
LanWalla@aol.com
Phone :
516-938-5007
Address :
Lance Wallach
www.vebaplan.org
www.TaxAudit419.com
IRS Form 8938
FATCA requires any U.S. person holding foreign financial assets with an aggregate value exceeding $50,000 to report certain information about those assets on a new form (Form 8938) that must be attached to the taxpayer’s annual tax return. Reporting applies for assets held in taxable years beginning on or after January 1, 2011. Failure to report foreign financial assets on Form 8938 will result in a penalty of $10,000 (and a penalty up to $50,000 for continued failure after IRS notification). Further, underpayments of tax attributable to non-disclosed foreign financial assets will be subject to an additional substantial understatement penalty of 40 percent.
Under FATCA, U.S. taxpayers holding financial assets outside the United States must report those assets to the IRS on a new form attached to their tax return. Penalties apply for failure to comply with this new reporting requirement. Reporting is required for assets held in taxable years beginning on or after January 1
Faculty Information
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INFORMATION:
PRACTICE AREAS: Tax
WEB SITE: http://www.vebaplan.org/
BIO:
Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, abusive tax shelters, financial, international tax, and estate planning. He writes about 412(i), 419, Section79, FBAR, and captive insurance plans. He speaks at more than ten conventions annually, writes for over fifty publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Pubic Radio’s All Things considered, and others. Lance has written numerous books including Protecting Clients from Fraud, incompetence and Scams published by John Wiley and Sons, Bisk Education’s CPA’s Guide to Life Insurance and Federal Estate and Gift Taxation, as well as the AICPA best-selling books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots. He does expert witness testimony and has never lost a case. Contact him at 516.938.5007, lawallach@aol.com or visit www.vebaplan.com.
Serving clients nationwide – Call us today: 516-938-5007 – Email: LanWalla@aol.com
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TAG ARCHIVES: LANCE WALLACH
Indian Business Man Prosecuted For Unreported HSBC India Account
Posted on February 24, 2014
by Brian M
Although all the media attention on unreported foreign accounts appears to focused on Switzerland, the Justice Department and IRS continue to look worldwide for U.S. taxpayers with undeclared offshore accounts. According to a press release from the United States Attorney’s Office, Sameer Gupta pleaded guilty last week to one count of tax evasion after the IRS discovered he had an unreported bank account at HSBC India. He faces 5 years in prison.
Possessing or having signature authority over an account in India is entirely legal if the account is reported annually to the IRS. Foreign bank and investment accounts must be reported each year on a Report of Foreign Bank and Financial Accounts, also known as an FBAR or form TD 90-22.1. Failure to file an FBAR is a felony.
Prosecutors say that in an effort to conceal his identity, Gupta had some 17 different bank accounts, several in nominee format. Opening an account in a false name or deliberately concealing one’s identity by opening an account in a third party name is considered an affirmative act of tax evasion.
Prosecutors say the tax loss caused by Gupta’s activities was somewhere between $200,000 and $400,000. As part of his plea deal, Gupta agreed to pay the IRS a $259,000 penalty. The judge can impose
ReplyDelete.
Reporting by U.S. Persons Holding Foreign Financia
Contact Information
Email :
LanWalla@aol.com
Phone :
516-938-5007
Address :
Lance Wallach
www.vebaplan.org
www.TaxAudit419.com
IRS Form 8938
FATCA requires any U.S. person holding foreign financial assets with an aggregate value exceeding $50,000 to report certain information about those assets on a new form (Form 8938) that must be attached to the taxpayer’s annual tax return. Reporting applies for assets held in taxable years beginning on or after January 1, 2011. Failure to report foreign financial assets on Form 8938 will result in a penalty of $10,000 (and a penalty up to $50,000 for continued failure after IRS notification). Further, underpayments of tax attributable to non-disclosed foreign financial assets will be subject to an additional substantial understatement penalty of 40 percent.
Under FATCA, U.S. taxpayers holding financial assets outside the United States must report those assets to the IRS on a new form attached to their tax return. Penalties apply for failure to comply with this new reporting requirement. Reporting is required for assets held in taxable years beginning on or after January 1
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FBAR OVDI Cause Americans Problems Over IRS Reporting Requirements
By Lance Wallach, CLU, CHFC
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ReplyDeleteThe complexity of life insurance puts many litigators at a disadvantage when disputes reach the stage of legal action. In addition, if policies are part of a retirement plan or other tax-favored entity, special rules apply. Even the methods of paying for life insurance—especially split-dollar and outside premium financing—affect an outcome. Tax implications are another factor.
Lance Wallach is one of few professionals who know how the pieces work both alone and with estate and financial planning. In many situations, what the client bought or the way that they bought it was inappropriate. In other cases the right product was sold in the right way but the purchaser is unhappy. Richard has the forensic ability to uncover what has taken place.
Working for both plaintiffs and defendants, depending on the merits of the case, Lance advises, opines, and testifies based upon the facts, his knowledge and experience. This makes him a very powerful and credible witness.
IRS Issues Final Sec. 6707A Regulations
ReplyDeleteOn September 2, 2011, the IRS issued final regulations concerning the section 6707A penalty. Such a penalty is imposed on taxpayers who fail to include any information regarding a reportable transaction which was required to be disclosed. The final regulations follow the statutory language of section 6707A as amended by the Small Business Jobs Act of 2010, but do not give further guidance regarding the Service’s computation of the penalty.
It is anticipated that such penalty computation guidance will be issued at a later date.(such guidance is expected by way of regulations that will be issued at a later date). Nonetheless, the final regulations do provide additional guidance concerning rescission of the penalty.
The attorneys of Williams Coulson regularly represent clients with section 6707A matters before the Internal Revenue Service. Please do not hesitate to contact
The complexity of life insurance puts many litigators at a disadvantage when disputes reach the stage of legal action. In addition, if policies are part of a retirement plan or other tax-favored entity, special rules apply. Even the methods of paying for life insurance—especially split-dollar and outside premium financing—affect an outcome. Tax implications are another factor.
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Can You Recover Money from 419 and 412i Plans?
By Lance Wallach, CLU, CHFC
Firm's Profile & ArticlesFirm's Profile & Articles
Find a Law Firm:
► Need a Lawyer? Let Us Help You
Welfare Benefit Plan Fraud: What Remedies Are Available? If you’ve been the victim of a 419 Welfare Benefit Plan scheme and now find yourself owing the Internal Revenue Service (IRS) taxes on something you were told was going to be tax deductible, it’s important to know what remedies might be available to you.
Remedies for abusive tax shelter schemes
Lance Wallach says that there are remedies for those who have been injured by an insurance company’s abusive tax shelter schemes. He predicts that we’ll see a huge spike in the number of people getting audited by the IRS.
Mediating 412(i) & 419 Claims: Can You Really Win?
You can win. However, to do so successfully, a mediator should have the proper background and team– a powerful combination that is sometimes hard to come by.
Having worked in almost every part of the life insurance industry for many years, Lance Wallach Is the Expert on tax shelter schemes involving Internal Revenue Code Sections 412(i) Pension Plans and Internal Revenue Code Section 419 Welfare Benefit Plans.
Unwinding abusive insurance transactions
There are not many firms who do what he does.
412(i) and 419 plans are generated by the insurance industry. So you’ve got to have knowledge about life insurance and the insurance industry first and foremost to understand the appeal of these transactions.
Consequently, that’s why Lance Wallach gets contacted from people all over the country that are at one stage or another in these plans who are trying to get out, get their tax issues taken care of and get their money paid back. He is an expert witness on different ongoing cases –and has never lost a case.
Working in conjunction with attorneys
Our firm will review your case and make an assessment on it for free. When clients hire him they get all the experts at one firm that know the landscape of both 412(1) and 419 plans, and all work tog
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