Trust Welfare Benefit - Multiple Employer Overview

"Over and over again, courts have held that there is nothing sinister in arranging one's affairs to keep taxes as low as possible. Everybody does so, rich and poor, and all do right because nobody owes any public duty to pay more than the law demands. Taxes are enforced extractions, not voluntary contributions."
...Judge Learned Hand

A multiple employer trust is authorized under Section 419A(f)(6) of the Internal Revenue code. This section helps chart a course to provide certain types of benefits for employees of the sponsoring employer.

A Welfare Benefit Trust can be established by virtually any corporation, large or small, for the benefit of its employees, including owner-employees and are utilized by thousands of businesses and professionals throughout the country.

The Welfare Benefit Trust provides an effective supplement to traditional qualified plans and an alternative to deferred compensation plans. For more information, Read On!

When properly structured a Welfare Benefit Trust can be designed so that the benefits paid from the trust will not be included in the estate for estate tax purposes. This is because the participants will have no "incidents of ownership" in the assets, including life insurance contracts held under the Welfare Benefit Trust. This is due to the following:

Wouldn't it be a shame to build a large pool of money and then lose it overnight, and probably not have enough time to rebuild that nest egg? While assets are held in a Welfare Benefit Trust, they may be protected from personal & business creditors.

The assets are not in any participant's name. In addition, regulations provide that the assets may never revert to the business and is for the exclusive benefit of the participants and their beneficiaries.

In 1989 & 1991 the tax court agreed that contributions made to a Welfare Benefit Plan which substantially exceeded the limitations of qualified plans, were permissible. In Moser vs. Commissioner and Joel A. Schneider, MD vs. Commissioner, the tax court upheld the taxpayer's position, even though 98% of the contributions were attributable to the benefit of Moser & Schneider. There is no statutory or regulatory provision that prohibits a deduction merely because a high portion of the benefits are attributable to one employee or a group of employees.

Other favorable cases that are noteworthy which were favorable to the tax payer and Welfare Benefit Plans are:

Because of the favorable benefits of a 419A(f)(6) Welfare Benefit Trust, we have found that the following businesses should consider establishing one:

The owner(s) of a prosperous small to medium sized business or professional corporation determine the amount of first year's contribution based upon their need to mitigate taxation and their need for tax deductible benefits. The contributions are fully deductible, as are the costs for establishing the plan. The value of the benefit is not included in the income of participants until paid out (exception, the economic value PS58 cost). The tax deferred and deductible employee benefits usually favor business and professional owner(s) because of the disparity in income and years of service. This ratio helps to keep the cost of the benefits to ancillary employees low. The trustee purchases life insurance benefits from highly rated and financially sound insurance carriers. Assets of the trust may be protected from personal & business creditors and may be estate tax exempt. A qualified 3rd party plan administrator does the plan administration while an independent trustee holds all assets of the trust. Our Welfare Benefit Plan is supported by a substantial authority legal opinion, which includes all current and relevant case law.

The last quarter of the year has typically been the time most advisors meet with clients who are facing a large tax liability, or who are seeking a way to contribute more than the current maximum under their qualified plan(s). Advisors limited by prior tax legislation share their frustration.

There is a plan to alleviate the frustrations of both the CPA/Attorney and Client. Its design allows contributions in excess of qualified plan limits. The payments are tax deductible. Plan assets are protected from creditors, and, under most circumstances with proper planning are exempt from estate tax. Distributions can be taken at any age without penalties. The program is fully insured and follows the guidelines as established by the Service and Judicial System.

It is a Multiple Employer Welfare Benefit Plan, created by Congress, which utilizes the limited exceptions of Section 419A(f)(6) to build benefits and reduce taxes.

WBP’s have been around for many years. Welfare trust benefits are available to LLC, C and S Corporations.

Unlike retirement or deferred compensation plans, the Welfare Benefit Trust (WBT) provides a unique benefit. In contrast to the above, which is triggered by the passage of time, the WBT becomes payable by reference to an event not in control of the recipient. In a qualified plan or deferred compensation plan, retirement is the triggering event The event that triggers the WBT is of an uncertain nature such as death, disability, health, etc.

There are other trusts available in the marketing community that look similar. In fact, they use similar marketing verbage. The promoters of these trusts imply that their favorable Letter of Determination offers the business owner a degree of security in the event of an IRS audit. Let me dispel this myth of tax exempt status offered by some 501(c)(9) promoters.

(1) The Deductibility of Employer Contributions: The determination letter states that no opinion is expressed or im-plied as to whether the employ-er’s contributions are deductible under the code.

(2) The Timing of Contributions and Taxation: The Letter of Determination for a 501(c)(9) trust states that no opinion is expressed or implied as to whether or not there is any provision available under the code that would permit in-dividuals to exclude from gross income contributions or pay-ments.

(3) The determination letter will not apply if the IRS, on audit, determines that the trust is discriminatory in operation on an employer by employer analysis. The Service has stated that the anti-discrimination and prohibited inurement require- ments of 501 (c) (9) regulations will be applied separately to each employer in a Multiple Employer 501 (c) (9) Trust. If one of the participant employers fails to satisfy such require- ments, the entire trust will lose its tax exempt qualification under Section 501 (c) (9). Further, the Service has concluded that if an employer with a small number of employees participates in a VEBA and provides a dominant share of an aggregate benefit to a prohibited group of employees, the prohibitive inurement test would be violated. Thus, most if not all, small employers in a 501 (c) (9) trust will fail the prohibitive inurement test. Failure to satisfy such tests will result in a termination of a tax exempt status.

In summary, protection offered by some VEBA 501 (c) (9) promoters is a myth. Please note, a Multiple Employer VEBA must also comply with Section 419A(f)(6). There have been numerous articles written regarding Welfare Benefit Plans. The consensus is, and I believe as well, that the Death Benefit Only Plan is superior. It doesn’t suffer from the disadvantages of prior case law, including the June 18, 1997 Booth Case (more on this in future newsletters).

The key is to find a plan possessing the intricate design characteristics which enables it to fit the limited exceptions of the law. One must also keep in mind that tax attorneys and CPAs did not create this tax planning opportunity, Congress did. As responsible advisors to our clients, we have the obligation to expose them to this idea and, where applicable, use it. It is the responsibility of the IRS to comply with the tax policy articulated by our elected representatives until, and if, the regulations are changed.

It is also the professional advisor’s responsibility to look for a Welfare Benefit Plan sponsor who reduces to writing and separately addresses com-plex legal issues. Professionals should not allow their un-familiarity with the Welfare Benefit Trust to impede their responsibility to provide clients with the best advice. Clients who can afford an annual con-tribution of $30,000 or more, are generally entrepreneurs by nature. They routinely endure risk, provided their advisors articulate the risk, thus allowing them the opportunity to make an informed decision.

In this first issue, I invite you to reflect upon this question. “If, in the appropriate

situation, we can provide you and your clients with substantial authority for deductibility of a Welfare Benefit Plan, how much would your clients want to contribute?”

So What Is This Strategy?

It is a Multiple Employer Welfare Benefit Plan, created by Congress, which utilizes the limited exceptions of Section 419A(f)(6) to build benefits and reduce taxes.

WBP’s have been around for many years. Welfare trust benefits are available to LLC, C and S Corporations.

What are the Advantages?

(for accumulating wealth)

· Tax deductible contributions

· Assets accumulate on a tax deferred basis.

· Flexible contributions

· Favorable towards the busi-ness owner

· Unlimited contributions

· No vesting for employees that prematurely terminate

Are There Other Plans?

A 501(c)(9) determination letter does not cover three critical issues:

EVALUATION OF A PLAN SPONSOR

In this first issue, I invite you to reflect upon this question. “If, in the appropriate

situation, we can provide you and your clients with substantial authority for deductibility of a Welfare Benefit Plan, how much would your clients want to contribute?”

The Welfare Benefit Trust

Provides An Effective

Alternative

Option 1

Owner receives $100,000 of income

Pays 40% in taxes

Net Spendable Income $60,000

(can invest or spend)

Option 2

Implements A Qualified Plan

Maximum Contribution $30,000

Option 3

Establish Welfare Benefit Trust

$100,000 Contribution

Deducted by the Business

$94,000 $6,000

Owner Benefits EE Benefits

THE PROBLEM

Business owners and pro-fessionals desiring to reduce taxes have been frustrated by the restrictions imposed by traditional qualified plans. These limitations restrict the amount of contribution into the Qualified Plan and the amount of future benefits paid.

What options are available for business owners and profes-sionals to fund existing insur-ance needs through their busi-ness or practice using tax de-ductible contributions?

THE ANSWER: FEW OR NONE!

A SOLUTION

The Welfare Benefit Trust is designed to assist business owners or professionals achieve tax deferred accumulation, while at the same time provide for tax deductible insurance premiums. Section 419A(f)(6) of the Internal Revenue Code permits the creation of a Multiple Employer Trust, known as a Welfare Benefit

Trust, that can be implemented to fund a specific benefit.

A properly established trust allows a business or professional corporation to obtain a current deduction for money contributed. A Welfare Benefit Trust is not subject to Qualified Plan limits. A Welfare Benefit Trust provides businesses and professionals with maximum flexibility.

AVAILABILITY

The Welfare Benefit Trust is utilized by LLC, C-Corporations and S-Corporations. The Trust is supported by legal and tax opinions with substantial authority and is administered by a highly qualified organization.

WHO SHOULD CONSIDER A WBT?

· Any profitable business or professional practice that wants a way to reduce tax liability.

· Corporations that can no longer make contributions to their qualified retirement plans because they are over-funded or no longer favor the business owner.

· Individuals who have estate

tax problems and wish to reduce or eliminate inheritance taxes.

· Individuals who would like to protect their assets from creditors. Especially those in a high risk business.

ADVANTAGES

When Fully Insured

Tax Deductible Contributions.

Assets Accumulate Tax-Deferred.

Contributions Are Flexible As To Amount

Favorable Towards Business Owner.

Protection of Assets From Creditors (under most circumstances).

Inexpensive To Set Up And Administer.

Permitted under the Internal Revenue Code

Unlimited Contributions.

Survivor Benefits Are Income Tax Exempt And Can Be Free Of Estate & Gift Tax.

· A multiple employer trust is authorized under Section 419A(f)(6) of the Internal Revenue Code. This ‘safe harbor’ is set up to provide certain types of benefits for employees of the sponsoring employer.

· A Welfare Benefit Trust can be established by virtually any large or small corporation for the benefit of its employees, including owner-employees. WBT’s are utilized by thousands of businesses and professionals throughout the country. There are more than 10,000 Welfare Benefit Plans in operation in the USA today.

· Welfare Benefit Trusts are one of the most powerful wealth preservation and tax deferral tools allowed by law.

· A Welfare Benefit Trust should not be regarded as a retirement plan or a form of deferred compensation.

· Any growth of Welfare Benefit Trust funds is tax deferred. If withdrawn from the trust, they are taxed as ordinary income.

As reported in the September 23, 1998 Wall Street Journal, the wealthiest 1 percent of Americans with income over $229,230 paid almost one-third of the nation’s total federal individual income taxes in 1996, up 25% a decade earlier. This elite group earns 16% of America’s income

Professional advisors, CPAs and Attorneys should not allow their unfamiliarity with new ideas to impede their judgment. It is your responsibility to provide your clients with innovative planning tools.

The key is: Education and Due Diligence. It is the obligation of a creditable Plan Sponsor of the Welfare Benefit Plan to provide the advisor with both.

· Conform to all the guidelines as handed down in Robert D. Booth v. Commissioner, 108 T.C., No. 25, June 17, 1997?

· Have legal and knowledgeable professionals to provide current and ongoing service?

When you are satisfied that you have selected a competent, well organized plan sponsor and program, one you can recommend with pride and a provider you can trust, then the next course of action is to ask:

3. Clients who want to accumulate substantial assets in excess of pension benefits.

7. Clients who need tax deductible life insurance premiums to fund estate planning needs

Our organization and professional associates are skilled in the design of tax oriented strategies. We can help you and your clients in resolving that on going year end question “How Can I Reduce My Taxes?”

W-2 income is utilized in a C Corporation for determining the multiple for benefit purposes. It is noteworthy that when there are several participating shareholders varying in age, compensation and need, the prohibitive group members, who generally are owners, can opt out of all or part of the life benefits. This allows the greatest versatility in planned design.

For example, all owners may earn the same income but may not want to participant at the same benefit level. In a C Corporation, they could simply adjust their W-2 income for benefit consideration purposes, thus allowing flexibility of individual choice.

Conversely, if a shareholder performs services for his/her Sub-S Corporation, draws no salary, and arranges for the corporation to pay him/her dividends, the IRS will properly classify those dividends as wages. REV ruling 74-44, 1974-1 CB287 held that dividends in lieu of salary are considered wages for FICA, FUTA and withholding tax purposes. The rulings of several recent district court cases and PLR 7949022 August 79 provide the authority that, if active shareholders receives dividends, K1 or undistributed taxable income, it constitutes compensation. As such, we believe all income may be used for purposes of determining the multiple of benefit in a Welfare Benefit Plan. (For a full explanation, E-mail, Fax or Call).

A contribution of $100,000 made by a Sub-S Corporation in the month of November 1998 creates a $40,000 tax saving that pass through to its sole shareholder. If the owner pays quarterly estimated taxes he/she can reduce his/her estimated payment by $10,000 per quarter in the following year. This results in increased cash flow that can be utilized for other purposes.

Shareholders of C and S Corporations have asked, “What, in your opinion, is the so-called ‘worst case scenario’ in the unlikely event the IRS is successful in the disallowance of corporate contributions?”

The corporation would have to pay income tax on the disallowed amounts in addition statutory interest for all the years still open under the 3-year statute of limitations. To the extent the deductions were claimed more than 3 years subsequent to the year under audit, those distributions would not generally be susceptible to disallowance.

The net economic effect of payment of interest could be mitigated by the annual increase in cash value of the insurance contract. In most instances, this should exceed the amount of interest paid to the IRS. Remember, the corporation would have been responsible to pay the same tax had it not adopted the Welfare Benefit Plan. Under §6662, there is a 20% accuracy related penalty unless the taxpayer can show reasonable reliance on an independent opinion by a qualified attorney or advisor.

In our plan, the taxpayer would be able to demonstrate good cause for claiming the deduction and the penalties will be abated under §6664(c). (For full explanation, E-mail, Fax or Call)

During the contribution phase, the IRS has a 3 year lookback, during which time the plan may be earning 7%-9% or more. Remember, a client’s only exposure is his/her tax bracket = 33% to 40%. During this period of time, the life insurance policy’s cash value has been growing at the highest current rate on 100% of the corporate contribution resulting in maximum tax efficiency.

I have been in practice for over 31 years. I cannot recall the IRS designing a significant tax deductible employee benefit program that would benefit the general public. Rather, the IRS takes the opposite position. It attempts to eliminate or control tax deductible ideas that creative planners have designed based on interpretation of the Code and judicial rulings. Welfare Benefit Plans are utilized by over 10,000 businesses (source-IRS) and have been in existence for many years. A WBP should be well designed to protect the client from any under-withholding penalty and, if necessary, provide an exit strategy.

By complying with all laws and regulations governing Welfare Benefit Plans and by practicing the highest standards of market conduct, we are determined to exceed the client’s expectations. We believe this strengthens our competitive advantage and enables us to focus on what is important.

In addition, this competitive advantage helps to develop relationships with clients and their advisors, providing them with appropriate advice, product and service. It is what is expected from us as experts in our field and it is our goal to deliver more than what is expected.

5. Survivor benefits that are income tax exempt and can be free of estate and gift tax

Our organization is comprised of a network of professionals who collectively offer a wide array of experience. This strategic alliance commits us to setting and maintaining the highest ethical standards of market conduct and sales practice in the design of tax oriented strategies.

We hope you have found our year end newsletters a helpful guide for you and your clients. There is still time in 1998 for your client’s to benefit from a year-end deduction

We know that many of you have been concerned about legislation pending in Congress that would have disallowed the use of permanent life insurance in a Welfare Benefit Plan. We are your Welfare Benefit Plan sponsor so be assured that we have been concerned right along with you. But now the dust has settled, President Clinton vetoed the Financial Freedom Act of 1999. Then on Friday, September 24th a proposal to include such legislation in a package of so-called “extender” bills was defeated. (Any bill affecting the way the IRS collects taxes has an absolute deadline of October 7th, after that there is not enough time to change the necessary forms.) Finally, GOP leaders appear to have little or no interest in trying to negotiate with the White House, trading off spending increases for a smaller tax cuts. They want to get out of town and prepare for next year’s elections.

Conventional wisdom holds that the tax cut issue and “coat-tail” issues, such as the one effecting permanent insurance in 419(a)(f)(6) plans, will not be re-addressed until the Summer of 2001, at the earliest. At the very least we have three(3) years of deductions: 1999, 2000, and 2001. This idea, to disallow permanent life insurance in WBP’s, seems to pop up every few years and is a classic “chilling” tactic used by the IRS to keep people from taking any action and to intimidate advisors. It follows like night follows day that the Service is not going to be in favor of an arrangement that keeps them from getting their hands on your client’s money. Do not be fooled into doing nothing, or advising others to do nothing...our Welfare Benefit Plan is alive and well...providing an excellent opportunity for your high-achieving small business clients to direct a portion of their income to a “safe harbor.” Using pre-tax dollars, business owners and their employees can purchase life insurance as part of their business planning, or as part of their personal estate planning, funding for estate taxes and estate liquidity. With a properly set up and administered WBP, death benefits can pass to loved ones completely free of income and estate taxes...the Service never gets to see the money. Would your high-achieving clients appreciate such a plan going forward into the new millennium?

The last quarter of the year is typically the time that most advisors are meeting with clients who are facing large income tax liabilities. Adviors are “under the gun,” seeking ways to reduce client’s taxes and thereby increase that client’s spendable or transferrable wealth. We all start to feel the frustration of seeing hard-earned dollars lost in the “black hole” of taxation. We need to disregard the chilling effect of threatened legislation and ACT. Remember, CPA’s and tax attorneys did not create the safe harbor offered by 419(a)(f)(6)...Congress did. It is the law. It is the responsibility of the IRS to comply with the tax policy articulated by our elected representatives. As responsible advisors, it is our obligation to educate our clients regarding available tax reduction strategies, such as tax-deductible life insurance, and where applicable, to seize the opportunity to utilize such plans to their benefit. A WBP is a win-win situation. Your client gets an almost unlimited income tax deduction, you get a satisfied customer...and because life insurance is the funding vehicle, that contribution together with accruals thereon may never be taxed. Everybody benefits...except the IRS.

But a WBP is Not For Everybody

We have referred herein to your high-achieving business clients. Here is the profile: The client must be a profitable corporation, able to make substantial contributions over a period of time, say $30,000 plus, for seven(7) or more years. The client should be in a position to make such a commitment without affecting their current life-style.(Groups of professionals are prime examples) The client must be able to tolerate some risk....A WBP is only appropriate for clients that do not require an absolute guarantee that deductions will never be challenged by the IRS. Keep in mind that clients who can afford an annual contribution of $30,000 or more are usually entrepreneurs by nature. They know there is never reward without risk. They routinely endure risk but want that risk articulated and weighed against the opportunity for reward...they want to make an informed decision. Qualified clients should obtain a second opinion letter from a qualified tax attorney that evaluates their specific situation. This letter should not come from the law firm that issued the WBP’s supporting Tax Opinion. A client-fact specific second opinion letter should eliminate the possibility of a penalty. Thus, the only risk remaining, if the deduction is challenged and your client does not want to meet that challenge, is that the deduction could be disallowed for the three(3) year “lookback” period . The corporation would be required to pay income taxes on the disallowed amounts plus interest.

Two factors mitigate this already minimal risk. First, since the company used pre-tax dollars to purchase cash-accruing (for the most part) life insurance, most of those dollars have been working to increase the cash value of that insurance. The insurance is in a trust and the trust will not have to pay taxes on its earnings. These earnings will, in most cases, exceed the amount of interest paid to the Service. And, the company pays the same tax it would have paid had it not adopted a Welfare Benefit Plan. Second, as to the “lost” deduction...it is not lost. The amounts paid for life insurance are deductible by the company in the year benefits are paid or the plan terminates, that is when an event taxable to an employee occurs. Thus a disallowed front-end deduction is taken in the year of a distribution or at termination. The issue is one of timing and your client is better served having adopted a Welfare Benefit Plan than not...Think About it.

Welfare Benefit Plans WBP exist to promote the public good. It is well settled that an employer can provide his employees with benefits in excess of mere compensation. These benefits serve the public purpose of increasing employee loyalty, stimulating productivity, and affording greater company stability. Thus, an employer can deduct as a reasonable and necessary business expense, the cost of providing these benefits.

When the benefit provided is life insurance the IRS gets its share every year the Plan is in effect because each employee-participant is responsible to pay taxes on the reportable economic benefit or PS58 cost of their participation. Thus, life insurance premiums are deductible by the employer and taxable to the employee albeit at a lesser rate provided in PS58. This is a logical and fair exchange, the employee pays a tax on a small amount, i.e. the reportable economic benefit and receives in exchange a larger tax-free death benefit. Thus is federal tax policy adhered to in a WBP.

Moreover, when the employee benefit provided is life insurance, the public good and federal tax policy is served by providing funds for the security and welfare of the survivors of adverse events such as death, disability, incapacity, or severe economic downturn. (See Section 101(a) IRC) WBPs promote the public good while complying with existing federal tax policy objectives.*

What is a Welfare Benefit Plan? Simply stated it is an employee benefit plan that provides for circumstances other than retirement or pension benefits. Welfare benefits can include death benefits, severance pay benefits, vision benefits medical and disability benefits. A WBP is not a pension or retirement plan, nor is it a form of deferred compensation in disguise. A WBP is a plan that provides a hedge against those unexpected, unforeseeable and uncontrollable events which all of us face. Such events as death, long-term disability, incapacity and extreme business adversity.

The distinction between a Welfare Benefit Plan and a retirement or deferred compensation plan is found in the event which triggers the payment of benefits. In the qualified plan or deferred compensation arrangement the triggering event is either foreseeable or in control of the participant such as retirement or the reaching of a certain age. In stark contrast, the triggering event in a WBP is of the uncertain variety…outside the control of the participant.

This distinction underlies the rationale for the favorable treatment of Welfare Benefit Plans. Congress has decided that while some tax revenues may be lost, the greater public good of providing for the security and welfare of the survivors of such unexpected adverse events, is realized. Do not forget that the IRS is taxing the premiums year in and year out pursuant to the PS58 schedule. It is a win-win situation.

The expected vs. the unexpected event reasoning also provides the basis for allowing an employer to alter, amend, or terminate a plan to meet the changing needs of employers and employees. With regard to termination and the distribution of Plan assets in the event of termination it should be noted that such distribution is not a plan benefit, rather it is the incidental result after plan benefits cease.

In a Welfare Benefit Plan you can mix permanent and term insurance. This allows permanent insurance for the most highly compensated employees and term insurance for others. So long as the benefits are proportional there is no discrimination. That is, when each participant’s life insurance policy is the same multiple of compensation there is no discrimination because should an participant die while the plan is in force his beneficiary receives the preset multiple of that participant’s compensation as a death benefit. This being true, the method chosen to fund the benefit, either term or permanent life insurance, is irrelevant to the operating characteristics of the plan. Therefore, the cost of providing the benefits is not relevant so long as the benefits themselves are a uniform multiple of compensation.

Further, commonly known actuarial data would seem to mandate to selection of permanent insurance for key employees. Data shows that an alarming number of highly paid professionals and executives suffer disabilities during their working lives. Prime examples are heart attacks, ulcers and other stress-related disorders. Such an unexpected event can render said key employee uninsurable and thus it is prudent business practice to choose permanent life insurance over term insurance for these employees.

Additionally, if a WBP were to be funded with only term insurance and the employer should experience an economic slowdown there might be no monies available to pay premiums and the plan would die. Everybody loses. On the other hand, a properly designed WBP mixing term and permanent insurance provides an unallocated reserve from which to draw premium payments during bad times. The result is that the plan and its benefits survive. The public good is again served.

A final word on permanent vs. term insurance as a funding vehicle for a WBP involves the ownership of policy cash values. Cash values are owned by the trust and not by the individual employee-participants. In the event a plan should be terminated for one reason or another, each participant employed at the time of termination is entitled a share of the cash value. This distribution is again proportional and based upon each employee’s total compensation against which a common multiplier is applied. A plan is not discriminate just because it provides one type of insurance to this group of employees and another type of insurance to another group, so long as all participating employees are eligible for benefits in the same proportion. This fairness theme underlies the delivery of benefits in a properly designed Welfare Benefit Plan.

In review, Welfare Benefit Plans exist to serve the public good by providing funds to meet needs, which arise out of unexpected adverse events. WBP’s work in harmony with qualified plans that provide for retirement and pension benefits. One provides for the planned event while the other provides for the unexpected emergency. Both are necessary for continued business stability, growth and prosperity.

Welfare Benefit Plans are Alive & Well

But a WBP is Not For Everybody

Why We Need the 419A(f)(6) Welfare Benefit Plan Funded with Permanent Life Insurance