Topic
Conservation Easements
399 published works
Legacy Advisors
IRS Offers Settlement to Syndicated Conservation Easement Investors with Cases Pending in U.S. Tax Court
By Barbara T. Kaplan, Josh Prywes, Michelle Ferreira, Scott E. Fink, Courtney A. Hopley, Shira Peleg, Jennifer A. Vincent
The IRS Office of Chief Counsel announced in Issue Number IR-2020-130 that it will be making a time-limited settlement offer to certain taxpayers with pending docketed Tax Court cases involving…
Nonprofit Law Prof Blog
IRS Offers settlements for Conservation Easements
The IRS just offered time limited settlements to those invested in conservation easements."The Internal Revenue Service Office of Chief Counsel announced today a time-limited settlement offer to certain taxpayers with…
Nonprofit Law Prof Blog
IRS Guidance for Syndicated Conservation Easement Exams (and Another Federal Appellate Court Victory)
Late last month the IRS publicly released an Interim Guidance Memorandum for Syndicated Conservation Easement Examinations. The memo focuses on how IRS Small-Business/Self-Employed Division and Large Business and International Division…
Rubin On Tax
Proportionate Means Proportionate
If a taxpayer contributes a conservation easement in land to a qualified organization, to obtain an income tax deduction the contribution must be in perpetuity. However, the law recognizes that…
Tax Controversy Report
IRS Continues Pressure on Syndicated Conservation Easements
The Internal Revenue Service is urging taxpayers involved in syndicated conservation easement transactions to consult with their tax advisors following a recent U.S. Tax Court decision. The IRS also plans…
Agricultural Law and Taxation Blog
Conservation Easements and the Perpetuity Requirement
OverviewI have done prior posts on conservation easements. In one post I dealt with the perpetuity requirement that must be satisfied for the donor to obtain a tax deduction for…
Nonprofit Law Prof Blog
IRS is Winning the Conservation Easement War – Or Is It?
Another week and another IRS victory in a conservation easement deduction dispute. This week the losing taxpayers were the individuals in Carter v. Commissioner, T.C. Memo. 2020-21. A partnership donated…
Legacy Advisors
Syndicated Conservation Easements: Under New Fire as IRS Enforcement Action Increases
By Michelle Ferreira, Barbara T. Kaplan, Jennifer A. Vincent
While the IRS has been cracking down on syndicated conservation easements for over ten years, earlier this year Chuck Rettig, the Commissioner of the IRS, announced several campaign areas upon…
Tax Controversy Report
IRS Steps Up the Pressure on Abusive Syndicated Conservation Easements
The Internal Revenue Service announced today a significant increase in enforcement actions for syndicated conservation easement transactions, a priority compliance area. According to the announcement, coordinated audits are being conducted throughout…
Wills, Trusts & Estates Prof Blog
Article on Private Land Conservation and Public Policy: Land Trusts, Land Owners, and Conservation Easements
Dominic P. Parker & Walter N. Thurman recently published an Article entitled, Private Land Conservation and Public Policy: Land Trusts, Land Owners, and Conservation Easements, Wills, Trusts, & Estates Law…