IRS tax relief firm, Lance Wallach, speaking: IRS tax relief firm, Lance Wallach, speaking: Help...: IRS tax relief firm, Lance Wallach, speaking: Help with Common IRS Problems: welfare benefit pla... : Help with Common IRS Problems: welfare...
LANCE WALLACH, CLU, ChFC
68 Keswick Lane
Plainview, New York 11803
Phone: (516) 938-5007 / 935-7346
Fax: (516)938-6330
~ National Society of Accountants Speaker of the Year
Education:
· Baruch College (CUNY), Baruch College Graduate School
· The American College – Chartered Financial Consultant (ChFC)· The American College – Chartered Life Underwriter (CLU)
Guest Lecturer for:
· Baruch College (Taxes on Tuesdays); Long Island University, C.W. Post Graduate School of Accountancy.
· Speaker at more than 70 conventions yearly, including the annual national conventions of the American Association of Attorney Certified Public Accountants, National Society of Accountants, National Network of Estate Planning Attorneys, National Association of Tax Practitioners, National Association of Enrolled Agents, National Association of Health Underwriters, American Society of Pension Actuaries, Employee Benefits Expo, Health Insurance Underwriters, NAPFA, NAIFA, FPA, NABA, ALPFA, various state CPA societies, Tax Institutes, as well a
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TAX / EMPLOYEE BENEFITS
Abusive Insurance and Retirement Plans
Single–employer section 419 welfare benefit plans are the latest incarnation in insurance deductions the IRS deems abusive
BY LANCE WALLACH
SEPTEMBER 2008
EXECUTIVE SUMMARY
Some of the listed transactions CPA tax practitioners are most likely to encounter are employee benefit insurance plans that the IRS has deemed abusive. Many of these plans have been sold by promoters in conjunction with life insurance companies.
As long ago as 1984, with the addition of IRC §§ 419 and 419A, Congress and the IRS took aim at unduly accelerated deductions and other perceived abuses. More recently, with guidance and a ruling issued in fall 2007, the Service declared as abusive certain trust arrangements involving cash-value life insurance and providing post-retirement medical and life insurance benefits.
The new "more likely than not" penalty standard for tax preparers under IRC § 6694 raises the stakes for CPAs whose clients may have maintained or participated in such a plan. Failure to disclose a listed transactio