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Section 419 Plans: The Problem That Never Ends
Fox Rothschild LLP Link to more items from this source
[Guidance Overview]
May 26, 2026

"Section 419 plans, marketed as legitimate tax deduction vehicles funded by whole life insurance, have been classified by the IRS as abusive tax shelters and consistently rejected by the courts. Plan sponsors face a 100% excise tax on disqualifying dispositions, leaving few legitimate exit strategies for those stuck with large insurance policies held in trust. Transferring plan sponsorship to a related entity that is then sold to a third party with legitimate welfare plan expenses may be the most viable option, though professional guidance is essential."  MORE >>

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