FBAR, OVDI, OPT-OUT, AMNESTY, 412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS,401K,IRS RED FLAG, 401KPENALTY
Every few years, individuals in the insurance industry conceive new tax-planning strategies that involve the sale olli~e. insurance. Frequently, the theories allOWing the tax treatmea! sought by the promoters are tenuous, and often the more insurance-particularly on the business owners-than is permissible under those incidental death benefit limita tions. This possible misuse ofSection 4/2(0 plans caused the IRS to categorize some 412(i) plans as "listed transac tions, " which require reporting to the IRS. Naiue taxpayers not reporting these listed transactions are now subject to horrendous perzafties. This month we discuss the impact of not reporting a 412(i) plan viewed by the IRS as a listed transaction with Roberta Casper Watson, a partner and head of the ERiSA Practice Group in the Tampa and St. Petersburg law firm of Trenam Kemker. She can be reached at rcwatson@trenam.com or 813-227-7474. A QWhat is the IRS focus on 4]2@ plans and reporting as a listed transaction? Let me first say that 412(i) plans are not always l
Every few years, individuals in the insurance industry
ReplyDeleteconceive new tax-planning strategies that involve the sale
olli~e. insurance. Frequently, the theories allOWing the tax
treatmea! sought by the promoters are tenuous, and often the more insurance-particularly on the business owners-than
is permissible under those incidental death benefit limita
tions. This possible misuse ofSection 4/2(0 plans caused
the IRS to categorize some 412(i) plans as "listed transac
tions, " which require reporting to the IRS. Naiue taxpayers
not reporting these listed transactions are now subject to
horrendous perzafties. This month we discuss the impact
of not reporting a 412(i) plan viewed by the IRS as a listed
transaction with Roberta Casper Watson, a partner and
head of the ERiSA Practice Group in the Tampa and
St. Petersburg law firm of Trenam Kemker. She can be
reached at rcwatson@trenam.com or 813-227-7474.
A
QWhat is the IRS focus on 4]2@ plans and
reporting as a listed transaction?
Let me first say that 412(i) plans are not always l