understand the mechanics and legal issues surrounding what has become known as “419 Plans,” welfare benefit plans often used by small companies and funded with life insurance. For that reason taxpayers throughout the country seek his services in dealing with the Internal Revenue Service in audits, appeals and in the Tax Court.
We can help you deal with: audits, appeals and Tax Court issues involving 419 Plan deductions and the taxation of withdrawals listed transaction issues including filing Form 8886 and fighting the section 6707A and section 6662A penalties See also: Captive Insurance Companies, 419 Plan Expert Witness and Life Insurance Trustee Risk Management. Picture Some of the Section 419 Welfare Benefit Plans: NOVA Benefit Plans (run or had been run by Dan Carpenter, Wayne Bursey, Guy Neumann, Kathy Kehoe, Joe Castagno and others), including: the SADI Plan, the Grist Mill Plan, Life One, among others Benistar Plans (also run or had been run by Dan Carpenter, Wayne Bursey, Guy Neumann, Kathy Kehoe, Joe Castagno and others) Greater Metropolitan Sterling Benefit Plan (run by Ronald Snyder) Millenium Plans CJA & Associates (run by Raymond Ankner) Sea Nine VEBA Compass Welfare Benefit Plan Sunderlage Resource Group/SRG International (run by Tracy Sunderlage, among others) Restricted Property Trust (RPT) (run by Ken Crabb)
Frankly, not everybody does it right. Whether through ignorance or ill-intent, some folks sell insurance based programs with tax benefits, such as 419 Plans and 412(i) Plans, or promote premium financing or STOLI programs to unsuspecting consumers leaving the consumer to be eaten alive, either by the IRS or by a turn in the economy, when all goes wrong. But the opposite is also true. Some 419 Plans and 412(i) Plan are very well designed and flawlessly implemented but the IRS just shoots first and aims second. Some legitimate premium financing might miscue.
+1 516.938.5007lance@expertwitness.taxNationwide - U.S.A Restricted Property Trusts Protect Yourself From IRS Audits HOME FILE FORM 8886 TODAY CONTACT US Welcome To Our Website for professionals and business entities who must comply with new IRS Notice requirements.
Failing to File Form 8886 for Vebas like Sea Nine Veba, or any 419, section 79, small Captives, or Restricted Property Trusts, creates multiple penalties!
The Form, IRS Form 8886 is required for all taxpayers who participate in a listed transaction such as a multiple employer welfare benefit program or 419 Plan.
If you are considering any of theses plans you need to take a few steps to protect yourself from potential audits from the IRS.
If you do not believe this Google Lance Wallach and whoever is advising you: YOU decide whom YOU Trust! Lance Wallach, National Society of Accountants, Speaker of the Year 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, Section 79, RPT, FBAR and Captive insurance plans.
Get Help Filing Form 8886 _ We make Filing This Form Painless!!! Get all Your Money Back From the IRS_ Protect Yourself from IRS Audits_ Call Today! Need Help? Contact Us Today!
Trust,Beta 419,Millennium Plan,Bisys,Creative Services Group,Sterling Benefit Plan,Compass 419,Niche 419,CRESP,Sea Nine Veba, American Benefits Trust, National Benefit Plan and Trust, ABT, Professional Benefits Trust Benistar 419 Plan, nova trust, Grist mill trust, Sadi Trust IRS raids, Millennium 419 Plan,Bisys 419,Creative Services Group 419 Plan,Sterling Benefit 419 Plan,CRESP 419,Sea Nine Veba 419, National Benefit Plan and Trust 419, American Benefits Trust 419,ABT 419,Old Mutual, Allmerica Financial, American Heritage Life, Commercial Union Life, National Life of Vermont, Old Line Life, Security Mutual Life, West Coast Life "Grist Mill Trust" "Real Veba""Section 79 GEAR" GEAR" "United Financial Group" "Kenny Hartstein" "Millennium Plan" Kenny Hartstein" "Millennium Plan" "Tom Crosswhite" "Greg Roper""captive insurance" cresp "Ridge Plan" "Professional benefits Trust" "PBT " "Professional Planning Associates" "National Pension Associate" "NPA""Heritage Plan" ""Insurance fraud""pension and benefit plan fraud""insurance company fraud""ECI Pension Services""Pension Professionals of America""ABI""Hartford""AIG""Indy Life""Indianapolis Life""Advantage" Names of People who SOLD: "Kenny Hartstein""Dennis Cunning""Steve Toth""Michael Sonnenberg"Larry Bell""Scott Ridge""Randall Smith""Greg Roper""Tracy Sunderlage""Warren Trust""Joseph Donnelly""Norm Bevan""Judy Carsrud""Dan Carpenter""Ed Waesche" "Tom Crosswhite""David Struckman""George Huff" "Tom Crosswhite" "Greg Roper""Christopher Jarvis" David Mandell" Gen Von Oder Insurance Companies -- need to be 412 AND 419: Hartford 419, Pacific Life 419, PAC Life 419, AVIVA, 419, Indianpolis Life, Penn Mutual419,Bankers Life 419, John Hancock 419, Security Mutual 419, Transamerica 419,Prudential 419, Kansas City Life 419, Mass Mutual419, Guardian 419, Amerus 419, Wells Fargo 419, Fifth Third Bank 419, Arrow Head Trust 419, U.S. Benefits Group, Benefit Plan Advisors, Rex Insurance Service,Advantage,AIG, Old Mutual, Allmerica Financial, American Heritage Life, Commercial Union Life, National Life of Vermont, Old Line Life, Security Mutual Life, West Coast Life
Trust,Beta 419,Millennium Plan,Bisys,Creative Services Group,Sterling Benefit Plan,Compass 419,Niche 419,CRESP,Sea Nine Veba, American Benefits Trust, National Benefit Plan and Trust, ABT, Professional Benefits Trust Benistar 419 Plan, nova trust, Grist mill trust, Sadi Trust IRS raids, Millennium 419 Plan,Bisys 419,Creative Services Group 419 Plan,Sterling Benefit 419 Plan,CRESP 419,Sea Nine Veba 419, National Benefit Plan and Trust 419, American Benefits Trust 419,ABT 419,Old Mutual, Allmerica Financial, American Heritage Life, Commercial Union Life, National Life of Vermont, Old Line Life, Security Mutual Life, West Coast Life "Grist Mill Trust" "Real Veba""Section 79 GEAR" GEAR" "United Financial Group" "Kenny Hartstein" "Millennium Plan" Kenny Hartstein" "Millennium Plan" "Tom Crosswhite" "Greg Roper""captive insurance" cresp "Ridge Plan" "Professional benefits Trust" "PBT " "Professional Planning Associates" "National Pension Associate" "NPA""Heritage Plan" ""Insurance fraud""pension and benefit plan fraud""insurance company fraud""ECI Pension Services""Pension Professionals of America""ABI""Hartford""AIG""Indy Life""Indianapolis Life""Advantage" Names of People who SOLD: "Kenny Hartstein""Dennis Cunning""Steve Toth""Michael Sonnenberg"Larry Bell""Scott Ridge""Randall Smith""Greg Roper""Tracy Sunderlage""Warren Trust""Joseph Donnelly""Norm Bevan""Judy Carsrud""Dan Carpenter""Ed Waesche" "Tom Crosswhite""David Struckman""George Huff" "Tom Crosswhite" "Greg Roper""Christopher Jarvis" David Mandell" Gen Von Oder Insurance Companies -- need to be 412 AND 419: Hartford 419, Pacific Life 419, PAC Life 419, AVIVA, 419, Indianpolis Life, Penn Mutual419,Bankers Life 419, John Hancock 419, Security Mutual 419, Transamerica 419,Prudential 419, Kansas City Life 419, Mass Mutual419, Guardian 419, Amerus 419, Wells Fargo 419, Fifth Third Bank 419, Arrow Head Trust 419, U.S. Benefits Group, Benefit Plan Advisors, Rex Insurance Service,Advantage,AIG, Old Mutual, Allmerica Financial, American Heritage Life, Commercial Union Life, National Life of Vermont, Old Line Life, Security Mutual Life, West Coast Life
We can help you deal with: audits, appeals and Tax Court issues involving 419 Plan deductions and the taxation of withdrawals listed transaction issues including filing Form 8886 and fighting the section 6707A and section 6662A penalties See also: Captive Insurance Companies, 419 Plan Expert Witness and Life Insurance Trustee Risk Management. Picture Some of the Section 419 Welfare Benefit Plans: NOVA Benefit Plans (run or had been run by Dan Carpenter, Wayne Bursey, Guy Neumann, Kathy Kehoe, Joe Castagno and others), including: the SADI Plan, the Grist Mill Plan, Life One, among others Benistar Plans (also run or had been run by Dan Carpenter, Wayne Bursey, Guy Neumann, Kathy Kehoe, Joe Castagno and others) Greater Metropolitan Sterling Benefit Plan (run by Ronald Snyder) Millenium Plans CJA & Associates (run by Raymond Ankner) Sea Nine VEBA Compass Welfare Benefit Plan Sunderlage Resource Group/SRG International (run by Tracy Sunderlage, among others) Restricted Property Trust (RPT) (run by Ken Crabb)
I was sitting in my office bored, which is what plan administration work will do to anyone, when the phone rang from our home office in Salt Lake City. The president of our company had a producer with him that had a client who was looking at a fully insured pension under 412 (e)(3) or a restrictive property trust.
“What?” I asked.
I have spent 30 years in tax law practice, three years in law school and taught as the lead faculty member for the Graduate Tax Program at Northeastern University and never saw restrictive property trust in the code or regulations.
I went to Google, which, of course, knows all. There in all its splendor were comments on the trust citing 419, section 83, 409 A. One website was bold enough to say they have a patent (even though this type of patent has been illegal for years). But, this type of plan has been dead since 2000 when the Third Circuit upheld Neonatology Associates v. Commissioner.
What confuses me is why anyone would persist to create a plan that, at best, will not work as well as a traditional pension, but more likely the deduction will be disallowed along with every penalty known to the IRS?
I prefer to follow the law as opposed to engage in “financial fantasies” (this was the wording the court used in Neonatology)
In a traditional pension, if you want to purchase insurance, you can use up to 50 percent of the pension contribution to purchase a whole life policy. Rev. Rul. 74-307, IRC section 401(a).
Second, if you want to purchase insurance you can use up to 50 percent of the pension contribution to purchase a whole life policy in a fully insured pension or 412 e 3 plan. Rev. Rul. 74-307.
Third, if you want to purchase insurance you can use up to 50 percent of the pension contribution in a cash balance plan to purchase a whole life policy. Rev. Rul 74-307.
Finally, if you do not like pensions, you can use up to 50 percent of the profit sharing contribution to purchase whole life insurance in the profit sharing plan. In all these cases, the purchase is 100 percent deductible (assuming at death the benefits are received as a taxable annuity).
Now, for the restrictive property trust, is this a plan under 419?-dead, section 83? or 409A? Have you read the 300 pages of regulations on 409A? The commentators are unclear. One claims to have a private letter ruling but does not publish it.
Before you engage in the financial fantasy think hard, do you want to buy a lawsuit? The plaintiff attorney is waiting for you!
The Restricted Property Trust is technically classified as a Welfare Benefit Plan. Welfare Benefit Plans are definitely nothing new. They actually date back to 1928, and come in many different names and forms.
There are currently 34 US States that use some form of a Welfare Benefit Plan for their State employees. What most people don’t know is that, ALL Welfare Benefit Plans must be related and/or associated to an actual welfare situation, such as death, disability, or disease.
Now the bad news is that, The Restrictive Property Trust is just a new-model 419-SCAM. The problem is that it’s a SCAM and nothing more.
In conjunction with Section 83, The Restrictive Property Trust makes the insurance tax-deductible going-in and tax-free coming-out, of course with some minor modifications.
Of course there is no such thing as a The Restrictive Property Trust in the Internal Revenue Code. The plan promoter claims a patent, etc., but in reality, tax-strategy patents were completely out-lawed sometime in 2011. Is his patent from the 90’s?
The downside of The Restrictive Property Trust is that the IRS requires a substantial risk of forfeiture because of no reason other than the fact that it is just another scam.
If you want to lose your money, put it in The Restrictive Property Trust. Shortly after the participants get audited they usually sue the salesman and insurance company. The promoters claim that they have a legal opinion. The IRS does not care and disallows the deduction.
The Restricted Property Trust is technically classified as a Welfare Benefit Plan. Welfare Benefit Plans are definitely nothing new. They actually date back to 1928, and come in many different names and forms.
There are currently 34 US States that use some form of a Welfare Benefit Plan for their State employees. What most people don’t know is that, ALL Welfare Benefit Plans must be related and/or associated to an actual welfare situation, such as death, disability, or disease.
Now the bad news is that, The Restrictive Property Trust is just a new-model 419-SCAM. The problem is that it’s a SCAM and nothing more.
In conjunction with Section 83, The Restrictive Property Trust makes the insurance tax-deductible going-in and tax-free coming-out, of course with some minor modifications.
Of course there is no such thing as a The Restrictive Property Trust in the Internal Revenue Code. The plan promoter claims a patent, etc., but in reality, tax-strategy patents were completely out-lawed sometime in 2011. Is his patent from the 90’s?
The downside of The Restrictive Property Trust is that the IRS requires a substantial risk of forfeiture because of no reason other than the fact that it is just another scam.
If you want to lose your money, put it in The Restrictive Property Trust. Shortly after the participants get audited they usually sue the salesman and insurance company. The promoters claim that they have a legal opinion. The IRS does not care and disallows the deduction.
Lance Wallach Lance Wallach Abusive tax shelters, 419, section 79, 412i micro captive insurance, VEBA, expert witness, author, speaker 24h Lance Wallach Lance Wallach Abusive tax shelters, 419, section 79, 412i micro captive insurance, VEBA, expert witness, author, speaker Interesting ideas are being touted as the latest and greatest uses of Life Insurance for obtaining enormous tax savings. This idea is not really new and makes use of certain tax codes eg. 419 and 419(e). The plans have typically used lousy life insurance plans (the plan works better that way) and the IRS has reviewed bits and pieces of this area of tax law for years. These RPT's may fall under Listed Transactions connected with Benefit Plans. Go for it but you CPA's out there make sure you have a ton of E & O insurance.
Notice 2007-83 - Abusive Trust Arrangements Utilizing Cash Value Life Insurance Policies Purportedly to Provide Welfare Benefits - 2007-45 I.R.B. 1 (transactions in which certain trust arrangements claiming to be welfare benefit funds and involving cash value life insurance policies that are being promoted to and used by taxpayers to improperly claim federal income and employment tax benefits (identified as “listed transactions” on October 17, 2007)).
The IRS finalized regulations on abusive tax shelters. ... A "listed transaction" is a transaction that is the same as, or substantially similar to, one that the IRS has determined to be a tax avoidance transaction and identified by IRS notice or other form of published guidance.Aug 27, 2017
restricted property trust get ur money back audits lawsuits Published on Published onDecember 11, 2017 Edit article View stats Stacey Arenas Stacey Arenas Assistant Managing Director, Marketing Manager at Vebaplan LLC 586 articles 71 Unlike 1 Comment 3
72 The Restricted Property Trust is technically classified as a Welfare Benefit Plan. Welfare Benefit Plans are definitely nothing new. They actually date back to 1928, and come in many different names and forms.
There are currently 34 US States that use some form of a Welfare Benefit Plan for their State employees. What most people don’t know is that, ALL Welfare Benefit Plans must be related and/or associated to an actual welfare situation, such as death, disability, or disease.
Now the bad news is that, The Restrictive Property Trust is just a new-model 419-SCAM. The problem is that it’s a SCAM and nothing more.
In conjunction with Section 83, The Restrictive Property Trust makes the insurance tax-deductible going-in and tax-free coming-out, of course with some minor modifications.
Of course there is no such thing as a The Restrictive Property Trust in the Internal Revenue Code. The plan promoter claims a patent, etc., but in reality, tax-strategy patents were completely out-lawed sometime in 2011. Is his patent from the 90’s?
The downside of The Restrictive Property Trust is that the IRS requires a substantial risk of forfeiture because of no reason other than the fact that it is just another scam.
If you want to lose your money, put it in The Restrictive Property Trust. Shortly after the participants get audited they usually sue the salesman and insurance company. The promoters claim that they have a legal opinion. The IRS does not care and disallows the deduction.
Notice 2007-83 - Abusive Trust Arrangements Utilizing Cash Value Life Insurance Policies Purportedly to Provide Welfare Benefits - 2007-45 I.R.B. 1 (transactions in which certain trust arrangements claiming to be welfare benefit funds and involving cash value life insurance policies that are being promoted to and used by taxpayers to improperly claim federal income and employment tax benefits (identified as “listed transactions” on October 17, 2007)).
Trust,Beta 419,Millennium Plan,Bisys,Creative Services Group,Sterling Benefit Plan,Compass 419,Niche 419,CRESP,Sea Nine Veba, American Benefits Trust, National Benefit Plan and Trust, ABT, Professional Benefits Trust Benistar 419 Plan, nova trust, Grist mill trust, Sadi Trust IRS raids, Millennium 419 Plan,Bisys 419,Creative Services Group 419 Plan,Sterling Benefit 419 Plan,CRESP 419,Sea Nine Veba 419, National Benefit Plan and Trust 419, American Benefits Trust 419,ABT 419,Old Mutual, Allmerica Financial, American Heritage Life, Commercial Union Life, National Life of Vermont, Old Line Life, Security Mutual Life, West Coast Life "Grist Mill Trust" "Real Veba""Section 79 GEAR" GEAR" "United Financial Group" "Kenny Hartstein" "Millennium Plan" Kenny Hartstein" "Millennium Plan" "Tom Crosswhite" "Greg Roper""captive insurance" cresp "Ridge Plan" "Professional benefits Trust" "PBT " "Professional Planning Associates" "National Pension Associate" "NPA""Heritage Plan" ""Insurance fraud""pension and benefit plan fraud""insurance company fraud""ECI Pension Services""Pension Professionals of America""ABI""Hartford""AIG""Indy Life""Indianapolis Life""Advantage" Names of People who SOLD: "Kenny Hartstein""Dennis Cunning""Steve Toth""Michael Sonnenberg"Larry Bell""Scott Ridge""Randall Smith""Greg Roper""Tracy Sunderlage""Warren Trust""Joseph Donnelly""Norm Bevan""Judy Carsrud""Dan Carpenter""Ed Waesche" "Tom Crosswhite""David Struckman""George Huff" "Tom Crosswhite" "Greg Roper""Christopher Jarvis" David Mandell" Gen Von Oder Insurance Companies -- need to be 412 AND 419: Hartford 419, Pacific Life 419, PAC Life 419, AVIVA, 419, Indianpolis Life, Penn Mutual419,Bankers Life 419, John Hancock 419, Security Mutual 419, Transamerica 419,Prudential 419, Kansas City Life 419, Mass Mutual419, Guardian 419, Amerus 419, Wells Fargo 419, Fifth Third Bank 419, Arrow Head Trust 419, U.S. Benefits Group, Benefit Plan Advisors, Rex Insurance Service,Advantage,AIG, Old Mutual, Allmerica Financial, American Heritage Life, Commercial Union Life, National Life of Vermont, Old Line Life, Security Mutual Life, West Coast Life
Search
ReplyDeleteJobs
understand the mechanics and legal issues surrounding what has become known as “419 Plans,” welfare benefit plans often used by small companies and funded with life insurance. For that reason taxpayers throughout the country seek his services in dealing with the Internal Revenue Service in audits, appeals and in the Tax Court.
ReplyDeleteWe can help you deal with:
audits, appeals and Tax Court
issues involving 419 Plan deductions and the taxation of withdrawals
listed transaction issues including filing Form 8886 and fighting the section 6707A and section 6662A penalties
See also: Captive Insurance Companies, 419 Plan Expert Witness and Life Insurance Trustee Risk Management.
Picture
Some of the Section 419 Welfare Benefit Plans:
NOVA Benefit Plans (run or had been run by Dan Carpenter, Wayne Bursey, Guy Neumann, Kathy Kehoe, Joe Castagno and others), including: the SADI Plan, the Grist Mill Plan, Life One, among others
Benistar Plans (also run or had been run by Dan Carpenter, Wayne Bursey, Guy Neumann, Kathy Kehoe, Joe Castagno and others)
Greater Metropolitan
Sterling Benefit Plan (run by Ronald Snyder)
Millenium Plans
CJA & Associates (run by Raymond Ankner)
Sea Nine VEBA
Compass Welfare Benefit Plan
Sunderlage Resource Group/SRG International (run by Tracy Sunderlage, among others)
Restricted Property Trust (RPT) (run by Ken Crabb)
Frankly, not everybody does it right. Whether through ignorance or ill-intent, some folks sell insurance based programs with tax benefits, such as 419 Plans and 412(i) Plans, or promote premium financing or STOLI programs to unsuspecting consumers leaving the consumer to be eaten alive, either by the IRS or by a turn in the economy, when all goes wrong. But the opposite is also true. Some 419 Plans and 412(i) Plan are very well designed and flawlessly implemented but the IRS just shoots first and aims second. Some legitimate premium financing might miscue.
Delete+1 516.938.5007lance@expertwitness.taxNationwide - U.S.A
ReplyDeleteRestricted Property Trusts
Protect Yourself From IRS Audits
HOME FILE FORM 8886 TODAY CONTACT US
Welcome To Our Website for professionals and business entities who must comply with new IRS Notice requirements.
Failing to File Form 8886 for Vebas like Sea Nine Veba, or any 419, section 79, small Captives, or Restricted Property Trusts, creates multiple penalties!
The Form, IRS Form 8886 is required for all taxpayers who participate in a listed transaction such as a multiple employer welfare benefit program or 419 Plan.
If you are considering any of theses plans you need to take a few steps to protect yourself from potential audits from the IRS.
If you do not believe this Google Lance Wallach and whoever is advising you: YOU decide whom YOU Trust! Lance Wallach, National Society of Accountants, Speaker of the Year 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, Section 79, RPT, FBAR and Captive insurance plans.
Get Help Filing Form 8886 _ We make Filing This Form Painless!!! Get all Your Money Back From the IRS_ Protect Yourself from IRS Audits_ Call Today!
Need Help? Contact Us Today!
Office:516-938-5007 or Cell:516-236-8440
∞—∞—∞—∞—∞
IRS Form 8886
Trust,Beta 419,Millennium Plan,Bisys,Creative Services Group,Sterling Benefit Plan,Compass 419,Niche 419,CRESP,Sea Nine Veba, American Benefits Trust, National Benefit Plan and Trust, ABT, Professional Benefits Trust Benistar 419 Plan, nova trust, Grist mill trust, Sadi Trust IRS raids, Millennium 419 Plan,Bisys 419,Creative Services Group 419 Plan,Sterling Benefit 419 Plan,CRESP 419,Sea Nine Veba 419, National Benefit Plan and Trust 419, American Benefits Trust 419,ABT 419,Old Mutual, Allmerica Financial, American Heritage Life, Commercial Union Life, National Life of Vermont, Old Line Life, Security Mutual Life, West Coast Life "Grist Mill Trust" "Real Veba""Section 79 GEAR" GEAR" "United Financial Group" "Kenny Hartstein" "Millennium Plan" Kenny Hartstein" "Millennium Plan" "Tom Crosswhite" "Greg Roper""captive insurance" cresp "Ridge Plan" "Professional benefits Trust" "PBT " "Professional Planning Associates" "National Pension Associate" "NPA""Heritage Plan" ""Insurance fraud""pension and benefit plan fraud""insurance company fraud""ECI Pension Services""Pension Professionals of America""ABI""Hartford""AIG""Indy Life""Indianapolis Life""Advantage" Names of People who SOLD: "Kenny Hartstein""Dennis Cunning""Steve Toth""Michael Sonnenberg"Larry Bell""Scott Ridge""Randall Smith""Greg Roper""Tracy Sunderlage""Warren Trust""Joseph Donnelly""Norm Bevan""Judy Carsrud""Dan Carpenter""Ed Waesche" "Tom Crosswhite""David Struckman""George Huff" "Tom Crosswhite" "Greg Roper""Christopher Jarvis" David Mandell" Gen Von Oder Insurance Companies -- need to be 412 AND 419: Hartford 419, Pacific Life 419, PAC Life 419, AVIVA, 419, Indianpolis Life, Penn Mutual419,Bankers Life 419, John Hancock 419, Security Mutual 419, Transamerica 419,Prudential 419, Kansas City Life 419, Mass Mutual419, Guardian 419, Amerus 419, Wells Fargo 419, Fifth Third Bank 419, Arrow Head Trust 419, U.S. Benefits Group, Benefit Plan Advisors, Rex Insurance Service,Advantage,AIG, Old Mutual, Allmerica Financial, American Heritage Life, Commercial Union Life, National Life of Vermont, Old Line Life, Security Mutual Life, West Coast Life
ReplyDeleteTrust,Beta 419,Millennium Plan,Bisys,Creative Services Group,Sterling Benefit Plan,Compass 419,Niche 419,CRESP,Sea Nine Veba, American Benefits Trust, National Benefit Plan and Trust, ABT, Professional Benefits Trust Benistar 419 Plan, nova trust, Grist mill trust, Sadi Trust IRS raids, Millennium 419 Plan,Bisys 419,Creative Services Group 419 Plan,Sterling Benefit 419 Plan,CRESP 419,Sea Nine Veba 419, National Benefit Plan and Trust 419, American Benefits Trust 419,ABT 419,Old Mutual, Allmerica Financial, American Heritage Life, Commercial Union Life, National Life of Vermont, Old Line Life, Security Mutual Life, West Coast Life "Grist Mill Trust" "Real Veba""Section 79 GEAR" GEAR" "United Financial Group" "Kenny Hartstein" "Millennium Plan" Kenny Hartstein" "Millennium Plan" "Tom Crosswhite" "Greg Roper""captive insurance" cresp "Ridge Plan" "Professional benefits Trust" "PBT " "Professional Planning Associates" "National Pension Associate" "NPA""Heritage Plan" ""Insurance fraud""pension and benefit plan fraud""insurance company fraud""ECI Pension Services""Pension Professionals of America""ABI""Hartford""AIG""Indy Life""Indianapolis Life""Advantage" Names of People who SOLD: "Kenny Hartstein""Dennis Cunning""Steve Toth""Michael Sonnenberg"Larry Bell""Scott Ridge""Randall Smith""Greg Roper""Tracy Sunderlage""Warren Trust""Joseph Donnelly""Norm Bevan""Judy Carsrud""Dan Carpenter""Ed Waesche" "Tom Crosswhite""David Struckman""George Huff" "Tom Crosswhite" "Greg Roper""Christopher Jarvis" David Mandell" Gen Von Oder Insurance Companies -- need to be 412 AND 419: Hartford 419, Pacific Life 419, PAC Life 419, AVIVA, 419, Indianpolis Life, Penn Mutual419,Bankers Life 419, John Hancock 419, Security Mutual 419, Transamerica 419,Prudential 419, Kansas City Life 419, Mass Mutual419, Guardian 419, Amerus 419, Wells Fargo 419, Fifth Third Bank 419, Arrow Head Trust 419, U.S. Benefits Group, Benefit Plan Advisors, Rex Insurance Service,Advantage,AIG, Old Mutual, Allmerica Financial, American Heritage Life, Commercial Union Life, National Life of Vermont, Old Line Life, Security Mutual Life, West Coast Life
ReplyDelete
ReplyDeleteWe can help you deal with:
audits, appeals and Tax Court
issues involving 419 Plan deductions and the taxation of withdrawals
listed transaction issues including filing Form 8886 and fighting the section 6707A and section 6662A penalties
See also: Captive Insurance Companies, 419 Plan Expert Witness and Life Insurance Trustee Risk Management.
Picture
Some of the Section 419 Welfare Benefit Plans:
NOVA Benefit Plans (run or had been run by Dan Carpenter, Wayne Bursey, Guy Neumann, Kathy Kehoe, Joe Castagno and others), including: the SADI Plan, the Grist Mill Plan, Life One, among others
Benistar Plans (also run or had been run by Dan Carpenter, Wayne Bursey, Guy Neumann, Kathy Kehoe, Joe Castagno and others)
Greater Metropolitan
Sterling Benefit Plan (run by Ronald Snyder)
Millenium Plans
CJA & Associates (run by Raymond Ankner)
Sea Nine VEBA
Compass Welfare Benefit Plan
Sunderlage Resource Group/SRG International (run by Tracy Sunderlage, among others)
Restricted Property Trust (RPT) (run by Ken Crabb)
ReplyDeleteI was sitting in my office bored, which is what plan administration work will do to anyone, when the phone rang from our home office in Salt Lake City. The president of our company had a producer with him that had a client who was looking at a fully insured pension under 412 (e)(3) or a restrictive property trust.
“What?” I asked.
I have spent 30 years in tax law practice, three years in law school and taught as the lead faculty member for the Graduate Tax Program at Northeastern University and never saw restrictive property trust in the code or regulations.
I went to Google, which, of course, knows all. There in all its splendor were comments on the trust citing 419, section 83, 409 A. One website was bold enough to say they have a patent (even though this type of patent has been illegal for years). But, this type of plan has been dead since 2000 when the Third Circuit upheld Neonatology Associates v. Commissioner.
What confuses me is why anyone would persist to create a plan that, at best, will not work as well as a traditional pension, but more likely the deduction will be disallowed along with every penalty known to the IRS?
I prefer to follow the law as opposed to engage in “financial fantasies” (this was the wording the court used in Neonatology)
In a traditional pension, if you want to purchase insurance, you can use up to 50 percent of the pension contribution to purchase a whole life policy. Rev. Rul. 74-307, IRC section 401(a).
Second, if you want to purchase insurance you can use up to 50 percent of the pension contribution to purchase a whole life policy in a fully insured pension or 412 e 3 plan. Rev. Rul. 74-307.
Third, if you want to purchase insurance you can use up to 50 percent of the pension contribution in a cash balance plan to purchase a whole life policy. Rev. Rul 74-307.
Finally, if you do not like pensions, you can use up to 50 percent of the profit sharing contribution to purchase whole life insurance in the profit sharing plan. In all these cases, the purchase is 100 percent deductible (assuming at death the benefits are received as a taxable annuity).
Now, for the restrictive property trust, is this a plan under 419?-dead, section 83? or 409A? Have you read the 300 pages of regulations on 409A? The commentators are unclear. One claims to have a private letter ruling but does not publish it.
Before you engage in the financial fantasy think hard, do you want to buy a lawsuit? The plaintiff attorney is waiting for you!
The Restricted Property Trust is technically classified as a Welfare Benefit Plan. Welfare Benefit Plans are definitely nothing new. They actually date back to 1928, and come in many different names and forms.
ReplyDeleteThere are currently 34 US States that use some form of a Welfare Benefit Plan for their State employees. What most people don’t know is that, ALL Welfare Benefit Plans must be related and/or associated to an actual welfare situation, such as death, disability, or disease.
Now the bad news is that, The Restrictive Property Trust is just a new-model 419-SCAM. The problem is that it’s a SCAM and nothing more.
In conjunction with Section 83, The Restrictive Property Trust makes the insurance tax-deductible going-in and tax-free coming-out, of course with some minor modifications.
Of course there is no such thing as a The Restrictive Property Trust in the Internal Revenue Code. The plan promoter claims a patent, etc., but in reality, tax-strategy patents were completely out-lawed sometime in 2011. Is his patent from the 90’s?
The downside of The Restrictive Property Trust is that the IRS requires a substantial risk of forfeiture because of no reason other than the fact that it is just another scam.
If you want to lose your money, put it in The Restrictive Property Trust. Shortly after the participants get audited they usually sue the salesman and insurance company. The promoters claim that they have a legal opinion. The IRS does not care and disallows the deduction.
The Restricted Property Trust is technically classified as a Welfare Benefit Plan. Welfare Benefit Plans are definitely nothing new. They actually date back to 1928, and come in many different names and forms.
ReplyDeleteThere are currently 34 US States that use some form of a Welfare Benefit Plan for their State employees. What most people don’t know is that, ALL Welfare Benefit Plans must be related and/or associated to an actual welfare situation, such as death, disability, or disease.
Now the bad news is that, The Restrictive Property Trust is just a new-model 419-SCAM. The problem is that it’s a SCAM and nothing more.
In conjunction with Section 83, The Restrictive Property Trust makes the insurance tax-deductible going-in and tax-free coming-out, of course with some minor modifications.
Of course there is no such thing as a The Restrictive Property Trust in the Internal Revenue Code. The plan promoter claims a patent, etc., but in reality, tax-strategy patents were completely out-lawed sometime in 2011. Is his patent from the 90’s?
The downside of The Restrictive Property Trust is that the IRS requires a substantial risk of forfeiture because of no reason other than the fact that it is just another scam.
If you want to lose your money, put it in The Restrictive Property Trust. Shortly after the participants get audited they usually sue the salesman and insurance company. The promoters claim that they have a legal opinion. The IRS does not care and disallows the deduction.
Lance Wallach
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Abusive tax shelters, 419, section 79, 412i micro captive insurance, VEBA, expert witness, author, speaker
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Lance Wallach
Lance Wallach
Abusive tax shelters, 419, section 79, 412i micro captive insurance, VEBA, expert witness, author, speaker
Interesting ideas are being touted as the latest and greatest uses of Life Insurance for obtaining enormous tax savings. This idea is not really new and makes use of certain tax codes eg. 419 and 419(e). The plans have typically used lousy life insurance plans (the plan works better that way) and the IRS has reviewed bits and pieces of this area of tax law for years. These RPT's may fall under Listed Transactions connected with Benefit Plans. Go for it but you CPA's out there make sure you have a ton of E & O insurance.
Notice 2007-83 - Abusive Trust Arrangements Utilizing Cash Value Life Insurance Policies Purportedly to Provide Welfare Benefits - 2007-45 I.R.B. 1 (transactions in which certain trust arrangements claiming to be welfare benefit funds and involving cash value life insurance policies that are being promoted to and used by taxpayers to improperly claim federal income and employment tax benefits (identified as “listed transactions” on October 17, 2007)).
ReplyDeleteThe IRS finalized regulations on abusive tax shelters. ... A "listed transaction" is a transaction that is the same as, or substantially similar to, one that the IRS has determined to be a tax avoidance transaction and identified by IRS notice or other form of published guidance.Aug 27, 2017
ReplyDeleterestricted property trust get ur money back audits lawsuits
ReplyDeletePublished on Published onDecember 11, 2017
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Stacey Arenas
Stacey Arenas
Assistant Managing Director, Marketing Manager at Vebaplan LLC
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The Restricted Property Trust is technically classified as a Welfare Benefit Plan. Welfare Benefit Plans are definitely nothing new. They actually date back to 1928, and come in many different names and forms.
There are currently 34 US States that use some form of a Welfare Benefit Plan for their State employees. What most people don’t know is that, ALL Welfare Benefit Plans must be related and/or associated to an actual welfare situation, such as death, disability, or disease.
Now the bad news is that, The Restrictive Property Trust is just a new-model 419-SCAM. The problem is that it’s a SCAM and nothing more.
In conjunction with Section 83, The Restrictive Property Trust makes the insurance tax-deductible going-in and tax-free coming-out, of course with some minor modifications.
Of course there is no such thing as a The Restrictive Property Trust in the Internal Revenue Code. The plan promoter claims a patent, etc., but in reality, tax-strategy patents were completely out-lawed sometime in 2011. Is his patent from the 90’s?
The downside of The Restrictive Property Trust is that the IRS requires a substantial risk of forfeiture because of no reason other than the fact that it is just another scam.
If you want to lose your money, put it in The Restrictive Property Trust. Shortly after the participants get audited they usually sue the salesman and insurance company. The promoters claim that they have a legal opinion. The IRS does not care and disallows the deduction.
Notice 2007-83 - Abusive Trust Arrangements Utilizing Cash Value Life Insurance Policies Purportedly to Provide Welfare Benefits - 2007-45 I.R.B. 1 (transactions in which certain trust arrangements claiming to be welfare benefit funds and involving cash value life insurance policies that are being promoted to and used by taxpayers to improperly claim federal income and employment tax benefits (identified as “listed transactions” on October 17, 2007)).
ReplyDeleteTrust,Beta 419,Millennium Plan,Bisys,Creative Services Group,Sterling Benefit Plan,Compass 419,Niche 419,CRESP,Sea Nine Veba, American Benefits Trust, National Benefit Plan and Trust, ABT, Professional Benefits Trust Benistar 419 Plan, nova trust, Grist mill trust, Sadi Trust IRS raids, Millennium 419 Plan,Bisys 419,Creative Services Group 419 Plan,Sterling Benefit 419 Plan,CRESP 419,Sea Nine Veba 419, National Benefit Plan and Trust 419, American Benefits Trust 419,ABT 419,Old Mutual, Allmerica Financial, American Heritage Life, Commercial Union Life, National Life of Vermont, Old Line Life, Security Mutual Life, West Coast Life "Grist Mill Trust" "Real Veba""Section 79 GEAR" GEAR" "United Financial Group" "Kenny Hartstein" "Millennium Plan" Kenny Hartstein" "Millennium Plan" "Tom Crosswhite" "Greg Roper""captive insurance" cresp "Ridge Plan" "Professional benefits Trust" "PBT " "Professional Planning Associates" "National Pension Associate" "NPA""Heritage Plan" ""Insurance fraud""pension and benefit plan fraud""insurance company fraud""ECI Pension Services""Pension Professionals of America""ABI""Hartford""AIG""Indy Life""Indianapolis Life""Advantage" Names of People who SOLD: "Kenny Hartstein""Dennis Cunning""Steve Toth""Michael Sonnenberg"Larry Bell""Scott Ridge""Randall Smith""Greg Roper""Tracy Sunderlage""Warren Trust""Joseph Donnelly""Norm Bevan""Judy Carsrud""Dan Carpenter""Ed Waesche" "Tom Crosswhite""David Struckman""George Huff" "Tom Crosswhite" "Greg Roper""Christopher Jarvis" David Mandell" Gen Von Oder Insurance Companies -- need to be 412 AND 419: Hartford 419, Pacific Life 419, PAC Life 419, AVIVA, 419, Indianpolis Life, Penn Mutual419,Bankers Life 419, John Hancock 419, Security Mutual 419, Transamerica 419,Prudential 419, Kansas City Life 419, Mass Mutual419, Guardian 419, Amerus 419, Wells Fargo 419, Fifth Third Bank 419, Arrow Head Trust 419, U.S. Benefits Group, Benefit Plan Advisors, Rex Insurance Service,Advantage,AIG, Old Mutual, Allmerica Financial, American Heritage Life, Commercial Union Life, National Life of Vermont, Old Line Life, Security Mutual Life, West Coast Life
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ReplyDelete419 welfare benefit plan, sue and get your money back, fight IRS 3299 views, 21 likes
ReplyDeletePublished on August 9, 2018
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