On the morning of Dec. 20, 2022, we finally got a look at the language being negotiated in the 4,155 page Omnibus spending bill. Buried in the bill is new
Continue Reading Omnibus Bill Limits Conservation Easements, but the Long-Requested Safe-Harbor Does Not Apply to Current CasesIn a major victory before a 17-judge panel of the U.S. Tax Court, a Fox Rothschild litigation team led a successful challenge to an IRS rule and secured the reversal
Continue Reading Fox Rothschild Tax Litigation Team Topples IRS Conservation Easement RuleOn January 12, 2021, please join members of Fox’s Tax Controversy team for a review of recent developments in federal tax controversy and civil and criminal tax enforcement, as well
Continue Reading Fox Rothschild’s Fourth Annual Federal Tax Controversy Summit
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
Continue Reading IRS Continues Pressure on 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
Continue Reading IRS Steps Up the Pressure on Abusive Syndicated Conservation Easements
The IRS has been cracking down on conservation easement transactions for over ten years. Nevertheless, taxpayers have continued to claim charitable contribution deductions attributable to the donation of conservation easements
Continue Reading Conservation Easements: A Year End Review
The Internal Revenue Service Large Business and International division (LB&I) has announced the approval of five additional compliance campaigns. LB&I announced on January 31, 2017, the rollout of its first
Continue Reading LB&I Announces Five More Compliance Campaigns
In Wendell Falls Development, LLC v. Commissioner, T.C. Memo. 2018-45, the Tax Court denied a charitable contribution deduction for a taxpayer’s contribution of a conservation easement because the taxpayer
Continue Reading Conservation Easements: Charitable Deduction Disallowed Under “Substantial Benefits” Test
August brought three wins for taxpayers who donated conservation easements that were challenged by the IRS. In all of the cases, terms of the conservation easement deed document carried the
Continue Reading Courts Issue Victories to Conservation Easement Donors