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Charitable Donations Internal Revenue Service Tax Deductions

Cadwalader, Wickersham & Taft LLP

Getting Technical with Partnership Termination Rule

The Tax Court recently ruled that a new partnership (“New Shoals”) that is deemed to form on a technical termination may use a taxable year that starts on the date of the termination of the old partnership (“Old Shoals”),...more

Polsinelli

Tax Court Strikes out Smoltz and Klesko’s Big K SCE, but Provides Relief for Those Facing Fraud Allegations

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In the late 1990s, former Atlanta Braves players John Smoltz and Ryan Klesko formed Big K Farms (“Big K”), a partnership that, over the years, acquired approximately 1,500 acres of land in Georgia for around $4 million. From...more

Polsinelli

Easement Fund Victory on Perpetuity Will Result in More Attention on Valuation

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In the latest victory for taxpayers, the Tax Court determined that the Treasury failed to follow federal law in enacting a conservation easement perpetuity rule known as the “proceeds regulation.” The majority opinion held...more

Polsinelli

Bare Knuckle Conservation Easement Brawl Leaves Participants in Limbo

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Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more

Farella Braun + Martel LLP

The New Proposed Regulations on DAFs: Taxable Distributions and the Penalty Tax

Welcome to EO Radio Show - Your Nonprofit Legal Resource. In today's episode, the final episode on the new DAF regulations, Cynthia Rowland takes a close look at the new Proposed Regulations 53.4966-2 and -5, which cover the...more

Pullman & Comley, LLC

'Tis the Season for Giving Charitable Giving Through Donor Advised Funds

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Have you considered establishing a donor advised fund as part of your year end giving? A donor advised fund is a type of charitable giving vehicle that allows you to make an irrevocable contribution to a charitable...more

McDermott Will & Emery

West Coast Forum 2023 | Key Takeaways

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McDermott’s Private Client Practice led interactive discussions on a broad range of topics pertinent to ultra-high-net-worth families, their family office representatives and other advisors at our Private Client West Coast...more

Rivkin Radler LLP

Hospitals and Community Benefit: Senators See a Shortfall

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For many weeks, we’ve been hearing about the IRS’s plans to use the funding provided under the Inflation Reduction Act[i] to increase and expand its compliance and enforcement efforts with respect to the wealthy, high-income...more

McDermott Will & Emery

Weekly IRS Roundup October 2 – October 6, 2023

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 2, 2023 – October 6, 2023. ...more

Polsinelli

Conservation Easements: Palpable Fraud or Honest Mistakes? A Federal Jury Returns a Split Verdict

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On September 22, 2023 a federal jury convicted two promoters, CPA Jack Fisher and attorney James Sinnott, in the Department of Justice’s (“DOJ”) first criminal trial over allegedly abusive syndicated conservation easements...more

Schwabe, Williamson & Wyatt PC

Understanding Charitable Gifts

Charitable giving is a way for businesses and individuals to support the causes that align with their values while saving on taxes. This article will cover common questions associated with charitable giving that will...more

Rivkin Radler LLP

Should Closely Held Businesses Be Charitable?

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Faulty Framework? The question posed above is not intended to be rhetorical. Rather, it is one that the owners of a closely held business should consider thoroughly before transferring or committing any business assets to...more

Polsinelli

Slogans and Insults: Fisher Defendants Respond to the Government’s Novel Conservation Easement Case

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Last week, the first federal criminal trial related to syndicated conservation easement (“SCE”) deals began with impaneling the jury and opening statements. Each of the Fisher defendants on trial, Jack Fisher, James Sinnott,...more

Polsinelli

Government Asserts the Defendants Lied and Cheated the IRS out of over $1.3 Billion: The Government’s Opening Statement of the...

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The first criminal prosecution of syndicated conservation easement promoters began on July 18, 2023, with the government laying out its case against defendants Jack Fisher, James Sinnott, and Clayton Weibel.  A Department of...more

Rivkin Radler LLP

Strategies for Giving to a Favorite Charity

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You may already know about many of the amazing things the North Shore Land Alliance has done to protect our beloved Long Island. The mission of the Land Alliance is: “To conserve and safeguard Long island’s natural and...more

Kohrman Jackson & Krantz LLP

IRS Challenges Charitable Status of NIL Collectives, Casting Doubt on Donations to Support College Athletes

Is it charitable to donate to a group that facilitates opportunities for athletes at a particular college? The IRS thinks not. In a recent memo released from the office of the IRS Chief Counsel, the IRS asserts that this...more

Brownstein Hyatt Farber Schreck

Conservation Easements: Federal Safe Harbor Language for Extinguishment and Boundary Line Adjustments

On Dec. 29, 2022, the United States Congress passed the SECURE 2.0 Act of 2022 (SECURE Act 2.0). Section 605(d) of the SECURE Act 2.0 gave conservation easement donors a safe harbor to amend provisions relating to...more

Lathrop GPM

Valuable Lessons in Charitable Deductions

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A recent Tax Court case provides important guidance for donors and charities making and negotiating gifts of appreciated property. While generally donors who donate appreciated property to a public charity do not recognize...more

Freeman Law

Tax Court in Brief | Estate of Hoenshied v. Commissioner | Anticipatory Assignment of Income, Charitable Contribution Deduction,...

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Summary: In this 49-page opinion the Tax Court addresses a deficiency arising from the charitable contribution of appreciated shares of stock in a closely held corporation to a charitable organization that administers...more

ASKramer Law

How to Donate Cryptocurrency and Other Digital Assets to Charity

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Explosive growth in digital assets has left investors with real questions about how to donate cryptocurrency and non-fungible tokens. That the tax bills are high enough to generate this interest is clear evidence of the gains...more

Freeman Law

Tax Court in Brief | Cattail Holdings, LLC v. Comm’r | Conservation Easement “Protected in Perpetuity” and Supervisory Approval of...

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Summary: In September 2016 Dolomite Holdings 251, LLC (Dolomite), acquired a 723-acre tract of land in Virginia. On November 28, 2017, Dolomite contributed 207 acres of this tract (Property) to Cattail in exchange for a 100%...more

Freeman Law

Tax Court in Brief | Lim v. Comm'r | Disallowance of Charitable Contribution Deduction for Lack of Qualified Appraisal; Reasonable...

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Summary:  This case involves taxpayers, Calvin Lim and Helen Chu (together, “Petitioners”) federal income tax liabilities for 2016 and 2017 with respect to a disallowed charitable contribution deduction....more

Fox Rothschild LLP

IRS Cracks Down on Charitable Contributions of Cryptocurrency

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On January 13, 2023, the IRS issued Chief Counsel Memorandum 202302012 (the “CCM”) establishing new rules for donations of cryptocurrency. In the CCM, the IRS concluded that taxpayers must obtain a ‘qualified appraisal’ if...more

Polsinelli

$1.7 Trillion Spending Bill Drops the Hammer on Conservation Easements

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Only months after the U.S. Tax Court and the 6th Circuit Court of Appeals ruled that the IRS failed to adhere to the Administrative Procedures Act when it promulgated Notice 2017-10 and designated most Syndicated Conservation...more

Freeman Law

Tax Court in Brief | Brooks v. Comm’r | Charitable Contribution Deductions for Conservation Easement; Contemporaneous Written...

Freeman Law on

Tax Litigation:  The Week of December 19th, 2022, through December 23rd, 2022 Starer v. Comm’r, T.C. Memo. 2022-124 | December 20, 2022 |Wells, J. |Docket No. 615-13 Mamadou v. Comm’r, T.C. Memo. 2022-121 | December 20, 2022...more

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