The appeals court for the seventh circuit has affirmed the convictions of six defendants who conspired to defraud the United States by impeding and impairing the functions of the Internal Revenue Service ("IRS") and committed offenses against the United States, along with related fraud and tax offenses that included the marketing of charitable trusts that could be marketed to customers as a means of both estate planning and income tax minimization.
Citation: United States v. Michael A. Vallone et al.; Nos. 08-3690, 08-3759, 08-4076, 08-4246, 08-4320, 09-1864, 09-2174
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?
Restricted Property Trust Published on January 27, 2016 LikeRestricted Property Trust1Comment14ShareShare Restricted Property Trust3 Jeff Gerber Jeff Gerber FollowJeff Gerber Ins. Life Disability Long Term Care Health 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.
LikeRestricted Property TrustCommentShareShare Restricted Property Trust Report this FollowJeff Gerber Jeff Gerber Jeff Gerber Ins. Life Disability Long Term Care Health 8 articles 14 commentsNewest
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16s Lance Wallach Business Owner at National Offices of Lance Wallach Restrictive property trust, file 8886 to avoid IRS fines Published on January 4, 2017 LikeRestrictive property trust, file 8886 to avoid IRS fines1Comment14ShareShare Restrictive property trust, file 8886 to avoid IRS fines11 Stacey Arenas Stacey Arenas… See more LikeReply 16h Lance Wallach Business Owner at National Offices of Lance Wallach Before you engage in the financial fantasy think hard, do you want to buy a lawsuit? The plaintiff attorney is waiting for you! UnlikeReplyYou 16h Lance Wallach Business Owner at National Offices of Lance Wallach RPT , Captive insurance and other audit targets Published on January 4, 2017 LikeRPT , Captive insurance and other audit targets1Comment13ShareShare RPT , Captive insurance and other audit targets3 Stacey Arenas Stacey Arenas… See more LikeReply 16h Lance Wallach Business Owner at National Offices of Lance Wallach RPT , Captive insurance and other audit targets Published on January 4, 2017 LikeRPT , Captive insurance and other audit targets1Comment13ShareShare RPT , Captive insurance and other audit targets3 Stacey Arenas Stacey Arenas… See more LikeReply 1d Lance Wallach Business Owner at National Offices of Lance Wallach
The appeals court for the seventh circuit has affirmed the convictions of six defendants who conspired to defraud the United States by impeding and impairing the functions of the Internal Revenue Service ("IRS") and committed offenses against the United States, along with related fraud and tax offenses that included the marketing of charitable trusts that could be marketed to customers as a means of both estate planning and income tax minimization.
ReplyDeleteCitation: United States v. Michael A. Vallone et al.; Nos. 08-3690, 08-3759, 08-4076, 08-4246, 08-4320, 09-1864, 09-2174
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.
ReplyDeleteWhat 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?
Restricted Property Trust
ReplyDeletePublished on January 27, 2016
LikeRestricted Property Trust1Comment14ShareShare Restricted Property Trust3
Jeff Gerber
Jeff Gerber
FollowJeff Gerber
Ins. Life Disability Long Term Care Health
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.
LikeRestricted Property TrustCommentShareShare Restricted Property Trust
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FollowJeff Gerber
Jeff Gerber
Jeff Gerber
Ins. Life Disability Long Term Care Health
8 articles
14 commentsNewest
Leave your thoughts here…
16s
Lance Wallach
Business Owner at National Offices of Lance Wallach
Restrictive property trust, file 8886 to avoid IRS fines
Published on January 4, 2017
LikeRestrictive property trust, file 8886 to avoid IRS fines1Comment14ShareShare Restrictive property trust, file 8886 to avoid IRS fines11
Stacey Arenas
Stacey Arenas… See more
LikeReply
16h
Lance Wallach
Business Owner at National Offices of Lance Wallach
Before you engage in the financial fantasy think hard, do you want to buy a lawsuit? The plaintiff attorney is waiting for you!
UnlikeReplyYou
16h
Lance Wallach
Business Owner at National Offices of Lance Wallach
RPT , Captive insurance and other audit targets
Published on January 4, 2017
LikeRPT , Captive insurance and other audit targets1Comment13ShareShare RPT , Captive insurance and other audit targets3
Stacey Arenas
Stacey Arenas… See more
LikeReply
16h
Lance Wallach
Business Owner at National Offices of Lance Wallach
RPT , Captive insurance and other audit targets
Published on January 4, 2017
LikeRPT , Captive insurance and other audit targets1Comment13ShareShare RPT , Captive insurance and other audit targets3
Stacey Arenas
Stacey Arenas… See more
LikeReply
1d
Lance Wallach
Business Owner at National Offices of Lance Wallach