Abusive Tax Shelters & 419 Plans Lawsuits
412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.
412i-419 Plans FBAR_OVDI Court Case Reportable Transactions .com Captive Insurance About me
Gender Male Industry Consulting Occupation Expert Location United States Introduction Lance Wallach, CLU, ChFC, CEO & Pres. Veba Plan LLC Website: http://VebaPlan.com ****** Lance Wallach, Managing Director, is the nation's leading expert on employee benefit plans, tax problem resolution and IRS audit defense. Mr. Wallach is a member of the AICPA faculty of teaching professionals & a renowned national expert in many court cases. He is the author of many best selling financial & law books, including: * "Wealth Preservation Planning" by the National Society of Accountants * "The CPA's Guide to Federal Estate & Gift Taxation" published by Bisk * The AICPA's "The team approach to Tax,Financial & Estate planning." * "The CPA's Guide to Life Insurance" by Bisk CPEasy * Avoiding Circular 230 Malpractice Traps and Common Abusive Small Businesss Hot spots by the AICPA, author/moderator Lance Wallach **** 68 Keswick Lane Plainview, NY 11803 Ph.: (516)938-5007 Fax: (516)938-6330 www.vebaplan.com
Captive Insurance & 419 Plans Litigation 412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions,412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions,Captive Insurance,Captive Insurance Lawsuits,412i Lawsuits,419 lawsuits,412i Help,419 Help, IRS Audits,412i Problems,412i problems, Expert Witness Lance Wallach,412i Help,419 Help, Benistar Lawsuits, 412i lawsuits,419 lawsuits,
FRIDAY, APRIL 18, 2014 Posted by Lance Wallach at 8:01 AM 1 comment: Labels: 412i, 412i Benefit Plan, 412i Benefit Plans, 419 Plan, Abusive Insurance Products, Abusive Retirement Plans 412i, abusive transactions, appraisal services Older Posts Home Subscribe to: Posts (Atom) LANCE WALLACH IS A NATIONALLY RECOGNIZED EXPERT, AUTHOR, AICPA INSTRUCTOR AND SPEAKER. "Protecting Clients from Fraud, Incompetence, and Scams" published by John Wiley & Sons Mr. Wallach is the National Society of Accountant's Speaker of the Year and the author of numerous professional books, including: "Avoiding Circular 230 Malpractice Traps and Common Abusive Small Businesss Hot Spots" by the AICPA - author/moderator Lance Wallach The AICPA's "The team approach to Tax, Financial and Estate Planning." "The CPA's Guide to Life Insurance" by Bisk CPEasy "Wealth Preservation Planning" by the National Society of Accountants "The CPA's Guide to Federal and Estate Gift Taxation" published by Bisk GET OUR FREE $200K REPORT
Lance Wallach - Interview - TaxAudit419.com www.taxaudit419.com/Lance_Wallach.html Personal interview with financial and taxation expert Lance Wallach. Expert in 419 welfare benefit plans, 412i retirement plans, Section 79 insurance and captive ... CJA & Associates and 412i, 419, and Other Abusive Plans
wewanttoprofileyouinnewbook.blogspot.com/.../cja-associates-a... by Lance Wallach - in 57 Google+ circles Nov 27, 2012 - Lance Wallach is the leading expert on 412i, 419, Section 79 and Captive Insurance Plans. Lance has helped hundreds of people resolve their ... You've visited this page many times. Last visit: 3/12/14 Lance Wallach National Society of Accountants Speaker of The Year taxshelterpenalty.blogspot.com/.../lance-wallach-national-society-of.html Posted by Lance Wallach at 10:58 AM · Email ThisBlogThis!Share to TwitterShare to FacebookShare to ... April 24, 2012 By Lance Wallach, CLU, CHFC ... You and Lance Wallach +1'd this Money talks, and it says, 'Penny-pincher' - Newsday www.newsday.com › Lifestyle Newsday Sep 5, 2013 - Lance Wallach is a 'Vette vet who has a lot of drive. (Credit: Handout). Until I was in fifth grade we lived in Queensbridge, a low-income housing ... You've visited this page 2 times. Last visit: 3/12/14 Lance Wallach | Business Valuations.org business-valuations.org/tag/lance-wallach/ Feb 24, 2014 - America's Best-selling CPE Programs New BISK CPEasy™ CPE Self-Study Course Author/Moderator: Lance Wallach, CLU, CHFC, CIMC ...
FBAR/OVDI LANCE WALLACH FBAR Foreign Bank Account Reporting The IRS is assessing huge penalties for undisclosed foreign bank accounts, assets & income. Click for more info FBAR FILING DEADLING HAS BEEN EXTENDED
Tuesday, February 18, 2014 FBAR-What are You Hiding The collapse of Swiss bank secrecy, the IRS settlement with UBS, the criminal investigation of HSBC and the related IRS voluntary disclosure program all have put foreign bank accounts in the spotlight. Tens of thousands, if not hundreds of thousands, of U.S. taxpayers have foreign bank accounts. Some of those taxpayers opened their foreign bank account in order to hide m
. Reporting by U.S. Persons Holding Foreign Financia Contact Information Email : LanWalla@aol.com Phone : 516-983-5007 Address : Lance Wallach www.taxaudit419.com www.vebaplan.org IRS Form 8938 FATCA requires any U.S. person holding foreign financial assets with an aggregate value exceeding $50,000 to report certain information about those assets on a new form (Form 8938) that must be attached to the taxpayers annual tax return. Reporting applies for assets held in taxable years beginning on or after January 1, 2011. Failure to report foreign financial assets on Form 8938 will result in a penalty of $10,000 (and a penalty up to $50,000 for continued failure after IRS notification). Further, underpayments of tax attributable to non-disclosed foreign financial assets will be subject to an additional substantial understatement penalty of 40 percent. Under FATCA, U.S. taxpayers holding financial assets outside the United States must report those assets to the IRS on a new form attached to their tax return. Penalties apply for failure to comply with this new reporting requirement. Reporting is required for assets held in taxable years beginning on or after January 1
Wednesday, March 12, 2014 FBAR/OVDI LANCE WALLACH: FBAR Offshore Bank Accounts and Foreign Income Att... FBAR/OVDI LANCE WALLACH: FBAR Offshore Bank Accounts and Foreign Income Att...: FBAR Offshore Bank Accounts and Foreign Income Attacked by IRS
Lance Wallach shared this on Google+
Amazon.com: Lance Wallach: Books, Biography, Blog, Audiobooks ... www.amazon.com/Lance-Wallach/e/B002PCF57E Amazon.com Visit Amazon.com's Lance Wallach Page and shop for all Lance Wallach books and other Lance Wallach related products (DVD, CDs, Apparel). Check out ...
Captive Insurance & 419 Plans Litigation lancewallachchfc.blogspot.com/ Feb 27, 2014 - By Lance Wallach, Consultant & Expert Witness. Recent court cases have highlighted serious problems in welfare benefit plans issued by Nova ... Lance Wallach shared this on Google+
International Tax Division: FBAR, OVDI, Foreign Offshore Assets Veba Plan LLC Home Page About Us Resources Testimonials Contact Us Welcome FBAR/OVDI filing. $250. This week only! Is opting out right for you? Click here to find out!
FBAR international tax IRS after you?
IRS Offshore Voluntary Disclosure Program Reopens
Lance Wallach Council Member President, 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.
FBAR/OVDI LANCE WALLACH FBAR Foreign Bank Account Reporting The IRS is assessing huge penalties for undisclosed foreign bank accounts, assets & income. Click for more info FBAR FILING DEADLING HAS BEEN EXTENDED
Tuesday, March 4, 2014 FBAR- Is Your Bank Account A Secret June 30 2014 is the annual deadline for U.S. taxpayers, (including resident aliens) to timely reports of foreign financial accounts for year ending 2013. (Note that the reports must be received by that date so we advise sending them in a couple of weeks prior to that date). The report form (TD 90-22.1) known as an FBAR is due if a U.S. taxpayer has direct or indirect control over an offshore financial account (such as a bank / brokerage account or other investment, broadly defined) that had an account balance/s in aggregate of $10,000 or more at any time during the calendar year. Failure to file and for the IRS to receive an FBAR by June 30 may result in penalties which range from a warning letter (for reasonable cause) to $10,000 per year per account for "non-willful" violations (late but otherwise accurate filing not excused for reasonable cause), to the greater of $100,000 or 50% of the account balance per year per account for "willful" failure to file (knowing and intentional or willfully blind conduct) to criminal prosecution. There is an increasing likelihood that the IRS will seek the "willful" civil penalties for taxpayer's who have failed to file FBAR for years prior to 2012 and who have failed to come forward and enter the Offshore Voluntary Disclosure Program. The reasons for this are as follows: First, since 2009 there have been three (3) formal opportunities for U.S. taxpayers to come forward. There was the 2009, 2011, 2012 and now the 2013 programs.
Second, offshore banks have been sending out letters to U.S. based account holders requesting that they attest to compliance with FBAR reporting and closing some accounts for non-compliance. The due diligence provisions Foreign Account Tax Compliance Act (FATCA) are now in effect and offshore banks with U.S. correspondent banking agreements are scouring their records for U.S. account holders. These banks are requesting consent from U.S. ac
Once ignored, but now the focus of headl MARCH 28, 2014 BY LANCEWALLACH Once ignored, but now the focus of headlines across the spectrum of tax publications, Form TD F 90-22.1, the Report of Foreign Bank and Financial Accounts (FBAR) is used by U.S. persons to report a financial interest in or signature authority over certain foreign financial accounts. In 2003, the Internal Revenue Service was delegated FBAR enforcement authority in an attempt to improve abysmal FBAR compliance rates, estimated for 2001 to be less than 20 percent.[1] The information provided on the FBAR is required to be disclosed under the Bank Secrecy Act. The Bank Secrecy Act is essentially a criminal statute which has been used by government authorities to apprehend and prosecute money launderers, drug dealers and terrorists, in addition to those who purposefully evade taxes.[2] Considering the seriousness of the criminal activities which the Bank Secrecy Act aims to address, it is not surprising that violations in FBAR reporting can carry steep penalties – the steepest of which are reserved for “willful” violations.[3] In this context, willfulness means that the U.S. person actually knew of his or her FBAR obligations but intentionally failed to fulfill those obligations.[4] Generally, a taxpayer is only given notice of possible FBAR reporting obligations on a single line of the income tax return, which inquires: “At any time during [the tax year], did you have an interest in or a signature or other authority over a financial account in a foreign country, such as a bank account, securities account, or other financial account?”[5] The Service takes the position that checking “no” to this question when the taxpayer in fact should have filed an FBAR, is evidence of willfulness, which in turn, warrants increased penalty assessments for FBAR violations.[6] http://ow.ly/v8GXI
Related Captives and the Management of Risk “TRIP” In "finance" IRS Makes Taxpayers Aware of Many Scams That Will Get Them in Trouble In "Expert Witness" Offshore Money, FBAR International Tax a In "finance"
Contact Information Email : LanWalla@aol.com Phone : 516-938-5007 Address : Lance Wallach www.vebaplan.org www.TaxAudit419.com IRS Form 8938 FATCA requires any U.S. person holding foreign financial assets with an aggregate value exceeding $50,000 to report certain information about those assets on a new form (Form 8938) that must be attached to the taxpayer’s annual tax return. Reporting applies for assets held in taxable years beginning on or after January 1, 2011. Failure to report foreign financial assets on Form 8938 will result in a penalty of $10,000 (and a penalty up to $50,000 for continued failure after IRS notification). Further, underpayments of tax attributable to non-disclosed foreign financial assets will be subject to an additional substantial understatement penalty of 40 percent. Under FATCA, U.S. taxpayers holding financial assets outside the United States must report those assets to the IRS on a new form attached to their tax return. Penalties apply for failure to comply with this new reporting requirement. Reporting is required for assets held in taxable years beginning on or after January 1, 2011.
Acquired or inherited foreign stock or securities, such as bonds.
Do I need to report these on Form 8938?
Foreign stock or securities, if you hold them outside of a financial account, must be reported on Form 8938, provided the value of your specified foreign financial assets is greater than the reporting threshold that applies to you. If you hold foreign stock or securities inside of a financial account, you do not report the stock or securities on Form 8938. For more information regarding the reporting of the holdings of financial accounts, see FAQs 8 and 9.
I directly hold shares of a U.S. mutual fund that owns foreign stocks and securities.
Do I need to report the shares of the U.S. mutual fund or the stocks and securities held by the mutual fund on Form 8938?
If you directly hold shares of a U.S. mutual fund you do not need to report the mutual fund or the holdings of the mutual fund.
I have a financial account maintained by a U.S. financial institution (including U.S. mutual funds, IRAs and 401(K) Plans) that holds foreign stock and securities.
Do I need to report the financial account or its holdings?
You do not need to report a financial account maintained by a U.S. financial institution or its holdings. Examples of financial accounts maintained by U.S. financial institutions include: U.S. Mutual fund accounts IRAs (traditional or Roth) 401 (k) retirement plans Qualified U.S. retirement plans Brokerage accounts maintained by U.S. financial institutions The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.
Protecting Clients from Fraud, Incompetence and Scams (Google eBook)
Front Cover Lance Wallach John Wiley and Sons, Feb 22, 2010 - Business & Economics - 240 pages 3 Reviews
Protect your clients – and yourself – from all kinds of financial chicanery and stupidity with this vital new book
It doesn't matter if a financial error was made because of malice or ignorance – the end result is that you lose money. Luckily, you don't have to sit idly and take it. If you have Protecting Clients from Fraud, Incompetence and Scams, you can identify and avoid the dysfunctional sectors of the financial industry, steer clear of the fallout from the Madoff Era, and guide your clients to real, healthy, sustainable returns. This powerful book
Pinpoints dysfunctional sectors within the financial industry and offers advice against frauds and scammers Shows how a team approach to asset management can ward off financial predators Offers practical strategies and tools to combat client risk for Risk and Asset Management Offering insightful information to protect your clients from all sorts of frauds and incompetence, this essential guide equips you with tips and techniques to spot the red flags of fraud and prevent it before it starts.
More »
Preview this book » What people are saying
My review - Edit review Larger ImageSid Kess’ Practical Alternatives to Commonly Misused and Abused Small Business Tax Strategies: Insuring Your Client’s Future Author/Moderator: Lance Wallach, CLU, CHFC, CIMC Publisher: AICPA Availability: In Stock Description Table of Contents Reviews Description A perfect follow-up to “Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots,” this course was created by the renowned Sid Kess. Learn the best strategies for reducing taxes and building, conserving and passing wealth to the next generation while at the same time avoiding abusive strategies. Objectives: • Identify practical alternatives to abusive tax shelters • Understand how to integrate financial products as part of a retirement plan • Discover how to use innovative retirement and financial programs to improve business and personal financial wealth of your clients • Optimize your value in the planning process between your clients and their financial advisors Prerequisite: None Accepted for CFP® credit. See full description o Course Objectives o Introduction o Organization Chapter 6 - Latest Developments March 2008 Member of the Month
Lawyers, Law Firms, Legal InformationFind a Lawyer
List Your Firm Legal Jobs FOLLOW US Google+ Facebook Twitter Home Law Firms Legal Services Law Employment Students Associations Articles Publications Events Sign In Contact Find Legal Articles Submit
Expert Witnesses Recent articlesSubmit an articleBackLegal Articles RSS Feed Print Share on Twitter Share on Facebook Share on LinkedIn
FBAR OVDI Offshore Tax Issues By Lance Wallach, CLU, CHFC
In 2012 the IRS announced another offshore voluntary disclosure program (the 2012 OVDI). These programs offer reduced penalties in exchange for taxpayers’ voluntarily coming into compliance before the IRS is aware of their prior tax indiscretions.
The 2012 OVDI is patterned after the 2011 OVDI, but increases the maximum Report of Foreign Bank and Financial Accounts (FBAR)-related penalty from 25 percent to 27.5 percent of the highest account value at any time between 2003 and 2010. The IRS can terminate it at any time as to specific classes of taxpayers or as to all taxpayers. 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 have come in since the 2011 program closed last year will be able to be treated under the provisions of the new OVDI program. . The 2011 OVDI, brought in an additional 12,000 eligible taxpayers who filed original and amended tax returns and agreed to make payments (or good-faith arrangements to pay) for taxes, interest and accuracy-related penalties. The 2011 OVDI FBAR-related penalty framework required a 25 percent “FBAR-related” penalty equal to the highest value of the financial account between 2003 and 2010. Only one 25 percent offshore penalty is to be applied with respect to voluntary disclosures relating to the same financial account. The penalty may be allocated among the taxpayers with beneficial ownership making the voluntary disclosures in any way they choose. Potentially applicable penalties are identified in a series of Frequently Asked Questions available at irs.gov. Participants in the 2011 OVDI also had to pay back-taxes and interest for up to eight years as well as paying accuracy-related and/or delinquency penalties. Subject to certain limitations, financial transactions occurring before 2003 were generally irrelevant for those participating in the OVDI.
Under the 2011 OVDI, taxpayers who are foreign residents and who were unaware they were U.S. citizens may qualified for a reduced five percent FBAR-related penalty (FAQ 52). Others qualified for the five percent penalty if they:
a. Did not open or cause the account to be opened (unless the bank required that a new account be opened, rather than allowing a change in ownership
FBAR/OVDI LANCE WALLACH FBAR Foreign Bank Account Reporting The IRS is assessing huge penalties for undisclosed foreign bank accounts, assets & income. Click for more info FBAR FILING DEADLING HAS BEEN EXTENDED
Wednesday, July 31, 2013 Check out my #constantcontact newsletter Check out my #constantcontact newsletter Posted by Lance Wallach at 12:10 PM No comments: Email This BlogThis! Share to Twitter Share to Facebook Share to Pinterest
Labels: 412(i), 419, Captive Insurance, Lance Wallach, Lance Wallach Expert Witness Monday, July 29, 2013 Issues with Potential Criminal Charges: Voluntary Disclosure-FBAR-OVDI IRS Information
New Filing Compliance Procedures for Non-Resident U.S. Taxpayers
The IRS is aware that some U.S. taxpayers living abroad have failed to timely file U.S. federal income tax returns or Reports of Foreign Bank and Financial Accounts (FBARs), Form TD F 90-22.1. Some of these taxpayers have recently become aware of their filing obligations and now seek to come into compliance with the law. The Service is announcing a new procedure for current non-residents including, but not limited to, dual citizens who have not filed U.S. income tax and information returns to file their delinquent returns. This procedure will go into effect on Sept. 1, 2012.
Description of proposed new procedure: While more details will be forthcoming, taxpayers utilizing the new procedure will be required to file delinquent tax returns, with appropriate related information returns, for the past three years and to file delinquent FBARs for the past six years. All submissions will be reviewed, but, as discussed below, the intensity of review will vary according to the level of compliance risk presented by the submission. For those taxpayers presenting low compliance risk, the review will be expedited and the IRS will not assert penalties or pursue follow-up actions. Submissions that present higher compliance risk are not eligible for the procedure and will be subject to a more thorough review and possibly a full examination, which in some cases may include more than three years, in a manner similar to opting out of the Offshore Voluntary Disclosure Program.
Unfiled Returns
The remedy is to get the returns filed
There are two advantages to filing as soon as possible: Generally, if a taxpayer is due a refund for withholding or estimated taxes paid, it must be claimed within 3 years of the return due date or risk losing the right to it. The same rule applies to a right to claim a tax credit such as the Earned Income Credit (EIC).
My blogs
ReplyDelete412i-419 Plans
FBAR_OVDI
Court Case
Reportable Transactions .com
Captive Insurance
About me
Gender Male
Industry Consulting
Occupation Expert
Location United States
Introduction Lance Wallach, CLU, ChFC, CEO & Pres. Veba Plan LLC Website: http://VebaPlan.com ****** Lance Wallach, Managing Director, is the nation's leading expert on employee benefit plans, tax problem resolution and IRS audit defense. Mr. Wallach is a member of the AICPA faculty of teaching professionals & a renowned national expert in many court cases. He is the author of many best selling financial & law books, including: * "Wealth Preservation Planning" by the National Society of Accountants * "The CPA's Guide to Federal Estate & Gift Taxation" published by Bisk * The AICPA's "The team approach to Tax,Financial & Estate planning." * "The CPA's Guide to Life Insurance" by Bisk CPEasy * Avoiding Circular 230 Malpractice Traps and Common Abusive Small Businesss Hot spots by the AICPA, author/moderator Lance Wallach **** 68 Keswick Lane Plainview, NY 11803 Ph.: (516)938-5007 Fax: (516)938-6330 www.vebaplan.com
Captive Insurance & 419 Plans Litigation
Delete412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions,412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions,Captive Insurance,Captive Insurance Lawsuits,412i Lawsuits,419 lawsuits,412i Help,419 Help, IRS Audits,412i Problems,412i problems, Expert Witness Lance Wallach,412i Help,419 Help, Benistar Lawsuits, 412i lawsuits,419 lawsuits,
FRIDAY, APRIL 18, 2014
Posted by Lance Wallach at 8:01 AM 1 comment:
Labels: 412i, 412i Benefit Plan, 412i Benefit Plans, 419 Plan, Abusive Insurance Products, Abusive Retirement Plans 412i, abusive transactions, appraisal services
Older Posts Home
Subscribe to: Posts (Atom)
LANCE WALLACH IS A NATIONALLY RECOGNIZED EXPERT, AUTHOR, AICPA INSTRUCTOR AND SPEAKER.
"Protecting Clients from Fraud, Incompetence, and Scams" published by John Wiley & Sons
Mr. Wallach is the National Society of Accountant's Speaker of the Year and the author of numerous professional books, including:
"Avoiding Circular 230 Malpractice Traps and Common Abusive Small Businesss Hot Spots" by the AICPA - author/moderator Lance Wallach
The AICPA's "The team approach to Tax, Financial and Estate Planning."
"The CPA's Guide to Life Insurance" by Bisk CPEasy
"Wealth Preservation Planning" by the National Society of Accountants
"The CPA's Guide to Federal and Estate Gift Taxation" published by Bisk
GET OUR FREE $200K REPORT
Lance Wallach - Interview - TaxAudit419.com
ReplyDeletewww.taxaudit419.com/Lance_Wallach.html
Personal interview with financial and taxation expert Lance Wallach. Expert in 419 welfare benefit plans, 412i retirement plans, Section 79 insurance and captive ...
CJA & Associates and 412i, 419, and Other Abusive Plans
wewanttoprofileyouinnewbook.blogspot.com/.../cja-associates-a...
by Lance Wallach - in 57 Google+ circles
Nov 27, 2012 - Lance Wallach is the leading expert on 412i, 419, Section 79 and Captive Insurance Plans. Lance has helped hundreds of people resolve their ...
You've visited this page many times. Last visit: 3/12/14
Lance Wallach National Society of Accountants Speaker of The Year
taxshelterpenalty.blogspot.com/.../lance-wallach-national-society-of.html
Posted by Lance Wallach at 10:58 AM · Email ThisBlogThis!Share to TwitterShare to FacebookShare to ... April 24, 2012 By Lance Wallach, CLU, CHFC ...
You and Lance Wallach +1'd this
Money talks, and it says, 'Penny-pincher' - Newsday
www.newsday.com › Lifestyle
Newsday
Sep 5, 2013 - Lance Wallach is a 'Vette vet who has a lot of drive. (Credit: Handout). Until I was in fifth grade we lived in Queensbridge, a low-income housing ...
You've visited this page 2 times. Last visit: 3/12/14
Lance Wallach | Business Valuations.org
business-valuations.org/tag/lance-wallach/
Feb 24, 2014 - America's Best-selling CPE Programs New BISK CPEasy™ CPE Self-Study Course Author/Moderator: Lance Wallach, CLU, CHFC, CIMC ...
FBAR/OVDI LANCE WALLACH
ReplyDeleteFBAR Foreign Bank Account Reporting The IRS is assessing huge penalties for undisclosed foreign bank accounts, assets & income. Click for more info FBAR FILING DEADLING HAS BEEN EXTENDED
Tuesday, February 18, 2014
FBAR-What are You Hiding
The collapse of Swiss bank secrecy, the IRS settlement with UBS, the criminal investigation of HSBC and the related IRS voluntary disclosure program all have put foreign bank accounts in the spotlight. Tens of thousands, if not hundreds of thousands, of U.S. taxpayers have foreign bank accounts. Some of those taxpayers opened their foreign bank account in order to hide m
.
ReplyDeleteReporting by U.S. Persons Holding Foreign Financia
Contact Information
Email :
LanWalla@aol.com
Phone :
516-983-5007
Address :
Lance Wallach
www.taxaudit419.com
www.vebaplan.org
IRS Form 8938
FATCA requires any U.S. person holding foreign financial assets with an aggregate value exceeding $50,000 to report certain information about those assets on a new form (Form 8938) that must be attached to the taxpayers annual tax return. Reporting applies for assets held in taxable years beginning on or after January 1, 2011. Failure to report foreign financial assets on Form 8938 will result in a penalty of $10,000 (and a penalty up to $50,000 for continued failure after IRS notification). Further, underpayments of tax attributable to non-disclosed foreign financial assets will be subject to an additional substantial understatement penalty of 40 percent.
Under FATCA, U.S. taxpayers holding financial assets outside the United States must report those assets to the IRS on a new form attached to their tax return. Penalties apply for failure to comply with this new reporting requirement. Reporting is required for assets held in taxable years beginning on or after January 1
Help with Common IRS Problems
ReplyDeleteMonday, February 17, 2014
419 Insurance Welfare Benefit Plans Get Accountants Into Trouble
419 Insurance Welfare Benefit Plans Get Accountants Into Trouble
412i-419 Plans
ReplyDelete419 & 412i benefit plan,abusive tax shelters, Lance Wallach Expert Witness
Wednesday, March 12, 2014
FBAR/OVDI LANCE WALLACH: FBAR Offshore Bank Accounts and Foreign Income Att...
FBAR/OVDI LANCE WALLACH: FBAR Offshore Bank Accounts and Foreign Income Att...: FBAR Offshore Bank Accounts and Foreign Income Attacked by IRS
Lance Wallach shared this on Google+
Amazon.com: Lance Wallach: Books, Biography, Blog, Audiobooks ...
www.amazon.com/Lance-Wallach/e/B002PCF57E
Amazon.com
Visit Amazon.com's Lance Wallach Page and shop for all Lance Wallach books and other Lance Wallach related products (DVD, CDs, Apparel). Check out ...
Captive Insurance & 419 Plans Litigation
lancewallachchfc.blogspot.com/
Feb 27, 2014 - By Lance Wallach, Consultant & Expert Witness. Recent court cases have highlighted serious problems in welfare benefit plans issued by Nova ...
Lance Wallach shared this on Google+
International Tax Division: FBAR, OVDI, Foreign Offshore Assets
ReplyDeleteVeba Plan LLC
Home Page
About Us
Resources
Testimonials
Contact Us
Welcome
FBAR/OVDI filing. $250.
This week only!
Is opting out right for you? Click here to find out!
FBAR international tax IRS after you?
IRS Offshore Voluntary Disclosure Program Reopens
Lance Wallach Council Member President, 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.
The Offices of Lance Wallach * 516-938-5007 * wallachinc@gmail.com
ReplyDeleteNationwide Assistance “abusive tax shelter help” "tax letter" "irs letter" "irs letters" "irs determination letter" 419e 412i 6707a "form 8886" "listed transactions" "abusive tax shelter assistance" "irs penalty abatement" "expert witness irs" veba "expert witness services" "expert witness irs help" "pension audit" "Grist Mill Trust" Benistar "SADI Trust" "Beta 419" "Millennium Plan" Bisys "Creative Services Group" "Sterling Benefit Plan" "Compass 419" Niche "Sea Nine Veba" 419 412i 419e "expert witness insurance" "welfare benefit plans" "419 plan help" "expert witness irs" “abusive tax shelter help” “irs appeal” “tax resolution services” “insurance expert witnesses” “pension plan audit” “tax preparer penalties” “tax audit defense” “business tax audit” “tax penalty abatement” “irs tax problems” “circular 230” “retirement tax shelters” “health insurance fraud” “employer insurance fraud” “irs trouble” “unfiled tax returns” “unfiled taxes” 419 412i "listed transactions" "form 8886" 6707A "tax shelters" "IRS audit defense" "expert witness irs help" "welfare benefit plan help" "419 plan help" "irs penalty abatement" "fight the irs" "412i retirement plans" "tax resolution services" "irs problem solvers" "how to avoid irs audit" "abusive tax shelter help"
Lance Wallachelter help"
Call:
516-938-5007
or
516-935-7346
Mr. "Lance Wallach"
FBAR/OVDI LANCE WALLACH
ReplyDeleteFBAR Foreign Bank Account Reporting The IRS is assessing huge penalties for undisclosed foreign bank accounts, assets & income. Click for more info FBAR FILING DEADLING HAS BEEN EXTENDED
Tuesday, March 4, 2014
FBAR- Is Your Bank Account A Secret
June 30 2014 is the annual deadline for U.S. taxpayers, (including resident aliens) to timely reports of foreign financial accounts for year ending 2013. (Note that the reports must be received by that date so we advise sending them in a couple of weeks prior to that date). The report form (TD 90-22.1) known as an FBAR is due if a U.S. taxpayer has direct or indirect control over an offshore financial account (such as a bank / brokerage account or other investment, broadly defined) that had an account balance/s in aggregate of $10,000 or more at any time during the calendar year.
Failure to file and for the IRS to receive an FBAR by June 30 may result in penalties which range from a warning letter (for reasonable cause) to $10,000 per year per account for "non-willful" violations (late but otherwise accurate filing not excused for reasonable cause), to the greater of $100,000 or 50% of the account balance per year per account for "willful" failure to file (knowing and intentional or willfully blind conduct) to criminal prosecution.
There is an increasing likelihood that the IRS will seek the "willful" civil penalties for taxpayer's who have failed to file FBAR for years prior to 2012 and who have failed to come forward and enter the Offshore Voluntary Disclosure Program. The reasons for this are as follows:
First, since 2009 there have been three (3) formal opportunities for U.S. taxpayers to come forward. There was the 2009, 2011, 2012 and now the 2013 programs.
Second, offshore banks have been sending out letters to U.S. based account holders requesting that they attest to compliance with FBAR reporting and closing some accounts for non-compliance. The due diligence provisions Foreign Account Tax Compliance Act (FATCA) are now in effect and offshore banks with U.S. correspondent banking agreements are scouring their records for U.S. account holders. These banks are requesting consent from U.S. ac
Once ignored, but now the focus of headl
ReplyDeleteMARCH 28, 2014 BY LANCEWALLACH
Once ignored, but now the focus of headlines across the spectrum of tax publications, Form TD F 90-22.1, the Report of Foreign Bank and Financial Accounts (FBAR) is used by U.S. persons to report a financial interest in or signature authority over certain foreign financial accounts. In 2003, the Internal Revenue Service was delegated FBAR enforcement authority in an attempt to improve abysmal FBAR compliance rates, estimated for 2001 to be less than 20 percent.[1] The information provided on the FBAR is required to be disclosed under the Bank Secrecy Act. The Bank Secrecy Act is essentially a criminal statute which has been used by government authorities to apprehend and prosecute money launderers, drug dealers and terrorists, in addition to those who purposefully evade taxes.[2] Considering the seriousness of the criminal activities which the Bank Secrecy Act aims to address, it is not surprising that violations in FBAR reporting can carry steep penalties – the steepest of which are reserved for “willful” violations.[3] In this context, willfulness means that the U.S. person actually knew of his or her FBAR obligations but intentionally failed to fulfill those obligations.[4] Generally, a taxpayer is only given notice of possible FBAR reporting obligations on a single line of the income tax return, which inquires: “At any time during [the tax year], did you have an interest in or a signature or other authority over a financial account in a foreign country, such as a bank account, securities account, or other financial account?”[5] The Service takes the position that checking “no” to this question when the taxpayer in fact should have filed an FBAR, is evidence of willfulness, which in turn, warrants increased penalty assessments for FBAR violations.[6] http://ow.ly/v8GXI
Related
Captives and the Management of Risk “TRIP”
In "finance"
IRS Makes Taxpayers Aware of Many Scams That Will Get Them in Trouble
In "Expert Witness"
Offshore Money, FBAR International Tax a
In "finance"
Contact Information
ReplyDeleteEmail :
LanWalla@aol.com
Phone :
516-938-5007
Address :
Lance Wallach
www.vebaplan.org
www.TaxAudit419.com
IRS Form 8938
FATCA requires any U.S. person holding foreign financial assets with an aggregate value exceeding $50,000 to report certain information about those assets on a new form (Form 8938) that must be attached to the taxpayer’s annual tax return. Reporting applies for assets held in taxable years beginning on or after January 1, 2011. Failure to report foreign financial assets on Form 8938 will result in a penalty of $10,000 (and a penalty up to $50,000 for continued failure after IRS notification). Further, underpayments of tax attributable to non-disclosed foreign financial assets will be subject to an additional substantial understatement penalty of 40 percent.
Under FATCA, U.S. taxpayers holding financial assets outside the United States must report those assets to the IRS on a new form attached to their tax return. Penalties apply for failure to comply with this new reporting requirement. Reporting is required for assets held in taxable years beginning on or after January 1, 2011.
Wednesday, May 8, 2013
ReplyDeleteFBAR QUESTIONS
Lance Wallach
Acquired or inherited foreign stock or securities, such as bonds.
Do I need to report these on Form 8938?
Foreign stock or securities, if you hold them outside of a financial account, must be reported on Form 8938, provided the value of your specified foreign financial assets is greater than the reporting threshold that applies to you. If you hold foreign stock or securities inside of a financial account, you do not report the stock or securities on Form 8938. For more information regarding the reporting of the holdings of financial accounts, see FAQs 8 and 9.
I directly hold shares of a U.S. mutual fund that owns foreign stocks and securities.
Do I need to report the shares of the U.S. mutual fund or the stocks and securities held by the mutual fund on Form 8938?
If you directly hold shares of a U.S. mutual fund you do not need to report the mutual fund or the holdings of the mutual fund.
I have a financial account maintained by a U.S. financial institution (including U.S. mutual funds, IRAs and 401(K) Plans) that holds foreign stock and securities.
Do I need to report the financial account or its holdings?
You do not need to report a financial account maintained by a U.S. financial institution or its holdings. Examples of financial accounts maintained by U.S. financial institutions include:
U.S. Mutual fund accounts
IRAs (traditional or Roth)
401 (k) retirement plans
Qualified U.S. retirement plans
Brokerage accounts maintained by U.S. financial institutions
The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.
Protecting Clients from Fraud, Incompetence and Scams (Google eBook)
ReplyDeleteFront Cover
Lance Wallach
John Wiley and Sons, Feb 22, 2010 - Business & Economics - 240 pages
3 Reviews
Protect your clients – and yourself – from all kinds of financial chicanery and stupidity with this vital new book
It doesn't matter if a financial error was made because of malice or ignorance – the end result is that you lose money. Luckily, you don't have to sit idly and take it. If you have Protecting Clients from Fraud, Incompetence and Scams, you can identify and avoid the dysfunctional sectors of the financial industry, steer clear of the fallout from the Madoff Era, and guide your clients to real, healthy, sustainable returns. This powerful book
Pinpoints dysfunctional sectors within the financial industry and offers advice against frauds and scammers
Shows how a team approach to asset management can ward off financial predators
Offers practical strategies and tools to combat client risk for Risk and Asset Management
Offering insightful information to protect your clients from all sorts of frauds and incompetence, this essential guide equips you with tips and techniques to spot the red flags of fraud and prevent it before it starts.
More »
Preview this book »
What people are saying
My review - Edit review
Larger ImageSid Kess’ Practical Alternatives to Commonly Misused and Abused Small Business Tax Strategies: Insuring Your Client’s Future
Author/Moderator: Lance Wallach, CLU, CHFC, CIMC
Publisher: AICPA
Availability: In Stock
Description
Table of Contents
Reviews
Description
A perfect follow-up to “Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots,” this course was created by the renowned Sid Kess. Learn the best strategies for reducing taxes and building, conserving and passing wealth to the next generation while at the same time avoiding abusive strategies.
Objectives:
• Identify practical alternatives to abusive tax shelters
• Understand how to integrate financial products as part of a retirement plan
• Discover how to use innovative retirement and financial programs to improve business and personal financial wealth of your clients
• Optimize your value in the planning process between your clients and their financial advisors
Prerequisite: None
Accepted for CFP® credit.
See full description
o Course Objectives
o Introduction
o Organization
Chapter 6 - Latest Developments
March 2008 Member of the Month
Lawyers, Law Firms, Legal InformationFind a Lawyer
ReplyDeleteList Your Firm
Legal Jobs
FOLLOW US
Google+
Facebook
Twitter
Home
Law Firms
Legal Services
Law
Employment
Students
Associations
Articles
Publications
Events
Sign In
Contact
Find Legal Articles
Submit
Expert Witnesses Recent articlesSubmit an articleBackLegal Articles RSS Feed Print
Share on Twitter Share on Facebook Share on LinkedIn
FBAR OVDI Offshore Tax Issues
By Lance Wallach, CLU, CHFC
Firm's Profile & ArticlesFirm's Profile & Articles
Find a Law Firm:
► Need a Lawyer? Let Us Help You
In 2012 the IRS announced another offshore voluntary disclosure program (the 2012 OVDI). These programs offer reduced penalties in exchange for taxpayers’ voluntarily coming into compliance before the IRS is aware of their prior tax indiscretions.
The 2012 OVDI is patterned after the 2011 OVDI, but increases the maximum Report of Foreign Bank and Financial Accounts (FBAR)-related penalty from 25 percent to 27.5 percent of the highest account value at any time between 2003 and 2010. The IRS can terminate it at any time as to specific classes of taxpayers or as to all taxpayers. 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 have come in since the 2011 program closed last year will be able to be treated under the provisions of the new OVDI program.
.
The 2011 OVDI, brought in an additional 12,000 eligible taxpayers who filed original and amended tax returns and agreed to make payments (or good-faith arrangements to pay) for taxes, interest and accuracy-related penalties. The 2011 OVDI FBAR-related penalty framework required a 25 percent “FBAR-related” penalty equal to the highest value of the financial account between 2003 and 2010. Only one 25 percent offshore penalty is to be applied with respect to voluntary disclosures relating to the same financial account. The penalty may be allocated among the taxpayers with beneficial ownership making the voluntary disclosures in any way they choose. Potentially applicable penalties are identified in a series of Frequently Asked Questions available at irs.gov. Participants in the 2011 OVDI also had to pay back-taxes and interest for up to eight years as well as paying accuracy-related and/or delinquency penalties. Subject to certain limitations, financial transactions occurring before 2003 were generally irrelevant for those participating in the OVDI.
Under the 2011 OVDI, taxpayers who are foreign residents and who were unaware they were U.S. citizens may qualified for a reduced five percent FBAR-related penalty (FAQ 52). Others qualified for the five percent penalty if they:
a. Did not open or cause the account to be opened (unless the bank required that a new account be opened, rather than allowing a change in ownership
FBAR/OVDI LANCE WALLACH
ReplyDeleteFBAR Foreign Bank Account Reporting The IRS is assessing huge penalties for undisclosed foreign bank accounts, assets & income. Click for more info FBAR FILING DEADLING HAS BEEN EXTENDED
Wednesday, July 31, 2013
Check out my #constantcontact newsletter
Check out my #constantcontact newsletter
Posted by Lance Wallach at 12:10 PM No comments:
Email This
BlogThis!
Share to Twitter
Share to Facebook
Share to Pinterest
Labels: 412(i), 419, Captive Insurance, Lance Wallach, Lance Wallach Expert Witness
Monday, July 29, 2013
Issues with Potential Criminal Charges: Voluntary Disclosure-FBAR-OVDI IRS Information
New Filing Compliance Procedures for Non-Resident U.S. Taxpayers
The IRS is aware that some U.S. taxpayers living abroad have failed to timely file U.S. federal income tax returns or Reports of Foreign Bank and Financial Accounts (FBARs), Form TD F 90-22.1. Some of these taxpayers have recently become aware of their filing obligations and now seek to come into compliance with the law. The Service is announcing a new procedure for current non-residents including, but not limited to, dual citizens who have not filed U.S. income tax and information returns to file their delinquent returns. This procedure will go into effect on Sept. 1, 2012.
Description of proposed new procedure:
While more details will be forthcoming, taxpayers utilizing the new procedure will be required to file delinquent tax returns, with appropriate related information returns, for the past three years and to file delinquent FBARs for the past six years. All submissions will be reviewed, but, as discussed below, the intensity of review will vary according to the level of compliance risk presented by the submission. For those taxpayers presenting low compliance risk, the review will be expedited and the IRS will not assert penalties or pursue follow-up actions. Submissions that present higher compliance risk are not eligible for the procedure and will be subject to a more thorough review and possibly a full examination, which in some cases may include more than three years, in a manner similar to opting out of the Offshore Voluntary Disclosure Program.
Unfiled Returns
The remedy is to get the returns filed
There are two advantages to filing as soon as possible:
Generally, if a taxpayer is due a refund for withholding or estimated taxes paid, it must be claimed within 3 years of the return due date or risk losing the right to it. The same rule applies to a right to claim a tax credit such as the Earned Income Credit (EIC).