Showing posts with label 419 lawsuits. Show all posts
Showing posts with label 419 lawsuits. Show all posts
Participated in a Sea Nine VEBA plan_Contact Lance Wallach: IRS Put 419 Plans and VEBA Plans on Top of its Hit...
Participated in a Sea Nine VEBA plan_Contact Lance Wallach: IRS Put 419 Plans and VEBA Plans on Top of its Hit...: There are some administrators still promoting 419 plans. It defies logic to me that sales people will sell something they know or should k...
robin weingast 419 audit google lance wallach for more
robin weingast 419 audit google lance wallach for more Summary
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412i-419 Plans: FBAR/OVDI LANCE WALLACH: FBAR Offshore Bank Accoun...
412i-419 Plans: FBAR/OVDI LANCE WALLACH: FBAR Offshore Bank Accoun...: FBAR/OVDI LANCE WALLACH: FBAR Offshore Bank Accounts and Foreign Income Att... : FBAR Offshore Bank Accounts and Foreign Income Attacked by ...
FBAR Offshore Bank Accounts and Foreign Income Attacked by IRS
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Offshore International Today Aug 2011
Lance Wallach
You may want to think about participation in the IRS' offshore tax amnestyprogram (called the Offshore Voluntary Disclosure Initiative). Do you want to play audit roulette with the IRS? Some clients think they are too small to be prosecuted. They are wrong.
To the average businessperson, only the guys with tens of millions secretly stashed in Swiss bank accounts get prosecuted. Don't tell that to Michael Schiavo. He was just prosecuted for hiding money in a Swiss account back in 2003. How much money does the IRS say he hid? A whopping $90,000. That's it.
But wait, there is more to the story. Schiavo attempted to do a quiet disclosure during the 2009 amnesty but instead of filling out the amnesty paperwork, he simply trusted that by coming forward voluntarily he could avoid criminal prosecution. He was wrong on all counts. Nothing is too small for the IRS, and nothing is too old.
"So, to save a whopping $40,624 in taxes, this guy risked a felony conviction and prison time, not to mention steep penalties that could very easily eat up the entire $90,000, and also his criminal and civil defense costs.
The smart taxpayers are the ones coming forward and not having to look over their shoulders for the next 10 years.
Time is running out. The tax amnesty runs through August but it takes at least days to jump through all the hoops. We will also fight hard to reduce the penalties down even more. Remember, the IRS can go as low as 5%. Don't want this to happen to you? Visit taxadvisorexpert.com today!
Lance Wallach, National Society of Accountants Speakerof the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters. He writes about 412(i), 419, 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 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, wallachinc@gmail.com or visit www.taxaudit419.com.
Taxlibrary
Taxlibrary
Learning Objectives
Introduction
Building the Perfect Retirement Plan
SEP IRA: The Good
SEP IRA: The Bad
SEP IRA: The Ugly
The K
The Double K
Defined Benefit Plans
Adding Survivor Benefits
412(i) Defined Benefit Plan
Cash Balance Plans
VEBAs and 419 Plans
Taxability of Trust Net Income
Taxability of Excess Benefits
Group-Term Life Insurance Plan
Post-Retirement Medical Benefit
Voluntary Employees Beneficiary Association (VEBA) - Commentary
New Development - Welfare Benefit Plans under Section 419(e)
Executive Carve Out Long-Term Care
What Is Long-Term Care?
How Much Does It Cost
Benefits of Long-Term Care Insurance to Employees
Benefits of Long-Term Care Insurance to Employers
Executive Carve Out Long-Term Care
Taxability
Long-Term Care Insurance Premium Deductibility
2007 Eligible Long-Term Care Insurance Premium
New and Bestselling AICPA CPE Self-Study Courses
At the AICPA Store you'll find more than 200 titles in a variety of formats to best meet your needs. Get practical guidance. Stay up-to-date on hot topics. Train your staff. Meet CPE reporting deadlines. Get real-time exam results with online grading. Check out this month's picks below. Turn to the AICPA for quality, value and convenience in CPE self-study products. Order today.
Author/Moderator: Lance Wallach, CLU, CHFC, CIMCPublisher: AICPA
Availability: In Stock
Chapter 1 - Planning for Business OwnersAt the AICPA Store you'll find more than 200 titles in a variety of formats to best meet your needs. Get practical guidance. Stay up-to-date on hot topics. Train your staff. Meet CPE reporting deadlines. Get real-time exam results with online grading. Check out this month's picks below. Turn to the AICPA for quality, value and convenience in CPE self-study products. Order today.
Author/Moderator: Lance Wallach, CLU, CHFC, CIMCPublisher: AICPA
Availability: In Stock
Learning Objectives
Introduction
Building the Perfect Retirement Plan
SEP IRA: The Good
SEP IRA: The Bad
SEP IRA: The Ugly
The K
The Double K
Defined Benefit Plans
Adding Survivor Benefits
412(i) Defined Benefit Plan
Cash Balance Plans
VEBAs and 419 Plans
Taxability of Trust Net Income
Taxability of Excess Benefits
Group-Term Life Insurance Plan
Post-Retirement Medical Benefit
Voluntary Employees Beneficiary Association (VEBA) - Commentary
New Development - Welfare Benefit Plans under Section 419(e)
Executive Carve Out Long-Term Care
What Is Long-Term Care?
How Much Does It Cost
Benefits of Long-Term Care Insurance to Employees
Benefits of Long-Term Care Insurance to Employers
Executive Carve Out Long-Term Care
Taxability
Long-Term Care Insurance Premium Deductibility
2007 Eligible Long-Term Care Insurance Premium
Abusive Tax Shelters & 419 Plans Lawsuits: FBAR/OVDI LANCE WALLACH: FBAR-What are You Hiding
Abusive Tax Shelters & 419 Plans Lawsuits: FBAR/OVDI LANCE WALLACH: FBAR-What are You Hiding: FBAR/OVDI LANCE WALLACH: FBAR-What are You Hiding : The collapse of Swiss bank secrecy, the IRS settlement with UBS, the criminal investiga...
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FBAR/OVDI filing. $250.
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FBAR international tax IRS after you?
IRS Offshore Voluntary Disclosure Program Reopens
Lance Wallach Council MemberPresident, VEBA Plan
Lance Wallach Council MemberPresident, VEBA Plan
Abusive Tax Shelter, Listed Transaction, Reportable Transaction Expert Witness Jan. 9, 2012 Today, the Internal Revenue Service reopened the offshore voluntary disclosure program to help people hiding offshore accounts get current with their taxes. Additionally, the IRS revealed the collection of more than $4.4 billion so far from the two previous international programs. The Offshore Voluntary Disclosure Program (OVDP) was reopened following continued strong interest from taxpayers and tax practitioners after the closure of the 2011 and 2009 programs. The third offshore program comes as the IRS continues working on a wide range of international tax issues and follows ongoing efforts with the Justice Department to pursue criminal prosecution of international tax evasion.
This program will remain open indefinitely until otherwise announced. Lance Wallach and his associates have received thousands of phone calls from concerned clients with questions about the prior programs. Some of Lance’s associates are still very busy helping people with the last program. Not a single person has been audited and most are pleased with the results and are now able to sleep easily without worrying about the IRS. According to Lance, it requires years of experience to obtain a good result from the program. He suggests using a CPA-certified, ex-IRS agent with lots of international tax experience. While this is not a requirement to file under the program, Lance has heard many horror stories from people who have tried to file by themselves or who have used inexperienced accountants.” Our focus on offshore tax evasion continues to produce strong, substantial results for the nation’s taxpayers,” said IRS Commissioner Doug Shulman. “We have billions of dollars in hand from our previous efforts, and we have more people wanting to come in and get right with the government. This new program makes good sense for taxpayers still hiding assets overseas and for the nation’s tax system.” The new program is similar to the 2011 program in many ways, but it has a few key differences. Unlike last year, there is no set deadline for people to apply. However, the terms of the program could change at any time going forward. For example, the IRS may increase penalties in the program for all or some taxpayers or defined classes of taxpayers – or decide to end the program entirely at any point.” As we've said all along, people need to come in and get right with us before we find you,” Shulman said. “We are following more leads and the risk for people who do not come in continues to increase. “The third offshore effort accompanies another announcement that Shulman made today, that the IRS has collected $3.4 billion so far from people who participated in the 2009 offshore program. That figure reflects closures of about 95 percent of the cases from the 2009 program. On top of that, the IRS has collected an additional $1 billion from up front payments required under the 2011 program. That number will grow as the IRS processes the 2011 cases. In all, the IRS has seen 33,000 voluntary disclosures from the 2009 and 2011 offshore initiatives. Since the 2011 program closed last September, hundreds of taxpayers have come forward to make voluntary disclosures. Those who come in after the closing of the 2011 program will be able to be treated under the provisions of the new OVDP program.
This program will remain open indefinitely until otherwise announced. Lance Wallach and his associates have received thousands of phone calls from concerned clients with questions about the prior programs. Some of Lance’s associates are still very busy helping people with the last program. Not a single person has been audited and most are pleased with the results and are now able to sleep easily without worrying about the IRS. According to Lance, it requires years of experience to obtain a good result from the program. He suggests using a CPA-certified, ex-IRS agent with lots of international tax experience. While this is not a requirement to file under the program, Lance has heard many horror stories from people who have tried to file by themselves or who have used inexperienced accountants.” Our focus on offshore tax evasion continues to produce strong, substantial results for the nation’s taxpayers,” said IRS Commissioner Doug Shulman. “We have billions of dollars in hand from our previous efforts, and we have more people wanting to come in and get right with the government. This new program makes good sense for taxpayers still hiding assets overseas and for the nation’s tax system.” The new program is similar to the 2011 program in many ways, but it has a few key differences. Unlike last year, there is no set deadline for people to apply. However, the terms of the program could change at any time going forward. For example, the IRS may increase penalties in the program for all or some taxpayers or defined classes of taxpayers – or decide to end the program entirely at any point.” As we've said all along, people need to come in and get right with us before we find you,” Shulman said. “We are following more leads and the risk for people who do not come in continues to increase. “The third offshore effort accompanies another announcement that Shulman made today, that the IRS has collected $3.4 billion so far from people who participated in the 2009 offshore program. That figure reflects closures of about 95 percent of the cases from the 2009 program. On top of that, the IRS has collected an additional $1 billion from up front payments required under the 2011 program. That number will grow as the IRS processes the 2011 cases. In all, the IRS has seen 33,000 voluntary disclosures from the 2009 and 2011 offshore initiatives. Since the 2011 program closed last September, hundreds of taxpayers have come forward to make voluntary disclosures. Those who come in after the closing of the 2011 program will be able to be treated under the provisions of the new OVDP program.
The overall penalty structure for the new program is the same for 2011, except for taxpayers in the highest penalty category.
The new program’s penalty framework requires individuals to pay a penalty of 27.5 percent of the highest aggregate balance in foreign bank accounts/entities or the value of foreign assets during the eight full tax years prior to the disclosure. That is up from 25 percent in the 2011 program. Some taxpayers will be eligible for 5 or 12.5 percent penalties; these remain the same in the new program as in 2011Participants must file all original and amended tax returns and include payment for back-taxes and interest for up to eight years as well as paying accuracy-related and/or delinquency penalties. The IRS recognizes that its success in offshore enforcement and in the disclosure programs has raised awareness related to tax filing obligations. This includes awareness by dual citizens and others who may be delinquent in filing, but owe no U.S. tax.
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 Public 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,wallachinc@gmail.com or visithttp://www.taxadvisorexpert.com.
IRS: Disclose Offshore Accounts or Go to Jail
Brian
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