|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.