412i, 419e plans litigation and IRS Audit Experts for abusive insurance reportable or listed transactions by the IRS,Section 79, Section 79 Lawsuits,412i
412i, 419e plans litigation and IRS Audit Experts for abusive insurance reportable or listed transactions by the IRS,Section 79, Section 79 Lawsuits,412i
An Expert Discusses Section 79 and Listed Transactions
ReplyDeleteThe dangers of being "listed"
A warning for 419, 412i, Sec.79 and captive insurance
As published in:
AccountingToday: October 25, 2010
By: Lance Wallach
Taxpayers who previously adopted 419, 412i, captive insurance or Section 79 plans are in big trouble.
In recent years, the IRS has identified many of these arrangements as abusive devices to funnel tax deductible dollars to
shareholders and classified these arrangements as "listed transactions."
These plans were sold by insurance agents, financial planners, accountants and attorneys seeking large life insurance
commissions. In general, taxpayers who engage in a "listed transaction" must report such transaction to the IRS on Form 8886
every year that they "participate" in the transaction, and you do not necessarily have to make a contribution or claim a tax
deduction to participate. Section 6707A of the Code imposes severe penalties ($200,000 for a business and $100,000 for an
individual) for failure to file Form 8886 with respect to a listed transaction.
But you are also in trouble if you file incorrectly.
Section 79 Scams and Captive Insurance History
ReplyDeleteWhen trying to understand how a product become