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Recognized Abusive and Listed Transactions

Abusive and Listed Transactions 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 […]

Restricted Property Trusts

Sent to me by Ken Crabb

After several years of legal battles with the IRS, we are thrilled to inform you that Restricted Property Trusts have been vindicated in the US Court of Appeals for the Sixth […]

Lack of Flexibility of Restricted Property Trust

Lack of Flexibility of Restricted Property Trust

A Restricted Property Trust can only be established by an S-Corp, C-Corp, LLC or Limited Partnership. Contributions to a Restricted Property Trust are a 100-percent deductible contribution under Internal Revenue […]

Strategy called Restricted Property Trust

Due to the history of the industry and the abuses, people were skeptical. After understanding of the mechanics it became clear that it was different than the “other” plans. Restricted […]

Notice 2007-83, Abusive Trust Arrangements

Notice 2007-83, Abusive Trust Arrangements

Abusive Trust Arrangements Utilizing Cash Value Life of Insurance Policies Purportedly to Provide Welfare Benefits – 2007-45 I.R.B. 1. Transactions in which different types of trust arrangements that are claiming […]

Abusive tax plans

From Forbes – Abusive tax plans

Originally published on Forbes.com Abusive tax plans For the last two decades Lance Wallach has been a voice crying out in the wilderness on the perils of 419(e) employee welfare plans. […]

Reportable Transaction Disclosure Statement

Reportable Transaction Disclosure Statement

Reportable Transaction Disclosure Statement Section references are to the Internal any series of steps carried out as part Participation in a Revenue Code unless otherwise noted. of a plan. Reportable […]

Restricted Property Trust

Restricted Property Trust

by Jeff Gerber Restricted Property Trust Ins. Life Disability Long Term Care Health Restricted Property Trust Interesting ideas are being touted as the latest and greatest uses of Life Insurance for […]

Pac Life suspends Section 79 plan sales

Pac Life suspends Section 79 plan sales

by Roccy DeFrancesco  on May 12, 2015 Pac Life suspends Section 79 plan sales I have just confirmed that Pacific Life Insurance suspended all sales of their Section 79 plan.  […]

RPT

RPT

by Nicholas Paleveda   RPT 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 […]

Disclosure of reportable transactions

You must disclose information for each reportable transaction in which you participate. See Reportable Transaction Disclosure Statement, later. Disclosure of reportable transactions Material advisors, with respect to any reportable transaction […]

Abusive Tax Shelters

Abusive Tax Shelters

Abusive tax shelters are marketing schemes involving artificial transactions with little or no economic reality. They often make use of unrealistic allocations, inflated appraisals, losses in connection with nonrecourse loans, […]

Tax Penalties

Tax Penalties

Tax Penalties Investing in an abusive tax shelter may lead to substantial expenses. First, the promoter generally charges a substantial fee. If your return is examined by the IRS and a […]

Authority for Disallowance of Tax Benefits

Authority for Disallowance of Tax Benefits

Authority for Disallowance of Tax Benefits The IRS has published guidance concluding that the claimed tax benefits of various abusive tax shelters should be disallowed. The guidance is the conclusion […]