Captive Insurance Plans
Captive Insurance Problems
California Broker, June 2011

Employee Retirement Plans

By Lance Wallach

412i, 419, Captive Insurance and Section 79 Plans; Buyer Beware

The IRS has been attacking all 419 welfare benefit plans, many 412i retirement plans, captive insurance plans with life insurance in them,
and Section 79 plans.  IRS is aggressively auditing various plans and calling them listed transactions, abusive tax shelters, or
reportable transactions, participation in any of which must be disclosed to the Service.  The result has been IRS audits, disallowances,
and huge fines for not properly reporting under IRC 6707A. 
Contact Information
Email :
Phone :
Address :
Lance Wallach and Ira Kaplan, ESQ