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Internal Revenue Service Appraisal

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
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

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

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

Appraiser Pleads Guilty to Fraud in Syndicated Conservation Easement Case

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Polsinelli’s Government Investigations and Tax attorneys continue to follow the well-known Fisher case, the Department of Justice’s ("DOJ") first criminal indictment related to syndicated conservation easements. Walter...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

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

Freeman Law

IRS CCMs on Crypto Donations and Crypto Losses

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IRS Chief Counsel Memoranda: Cryptocurrency Donations Above $5,000 Need Qualified Appraisal and No Unrealized Cryptocurrency Loss Without Disposition - Introduction - The IRS recently released two chief counsel...more

McDermott Will & Emery

NFTs and Charitable Fundraising: Navigating Tax Hurdles

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As the creation of and transactions involving non-fungible tokens (NFTs) have increased dramatically, so has interest in using NFTs as donations to charitable organizations and for other charitable fundraising tools. Given...more

Rivkin Radler LLP

Gifting Business Interests Before Selling the Business? Think Valuation

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Counting the Days?- We are 302 days away from the national mid-term elections, to be held November 8, 2022, yet the first full week of the new year has already highlighted some of the economic issues with which the...more

McDermott Will & Emery

Special Report - A Primer on Charitable Contributions of Virtual Currency

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The explosive growth in virtual currency (also referred to as cryptocurrency, digital assets, tokens and digital currency) is evidence of increasing popularity and acceptance of it as a new investment asset class. With the...more

Nutter McClennen & Fish LLP

Bank Report: November 2019

OCC and FDIC Propose Interest Rate Fix for Loans Transferred to Non-Banks - The FDIC and OCC have separately proposed rules that would codify the “valid-when-made” doctrine and clarify that when a bank sells, assigns, or...more

Farrell Fritz, P.C.

Valuation, Hindsight, And Taxes

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The Benefit of Knowing- Monday morning quarterbacking – the connotations are anything but positive. Life is full of instances in which someone, in possession of all the factors that informed – or that should have...more

Burr & Forman

Senate Finance Committee Probing Conservation Easement Abuse

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On March 27, 2019, the Senate Finance Committee launched an investigation into the abuse of syndicated conservation easement transactions. The transactions being investigated involve promoters selling interests in tracts of...more

Womble Bond Dickinson

How to Make Charitable Contribution Deductions Vanish in to Thin Air – a Review of the Charitable Contribution Substantiation...

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On July 27, 2018, the Treasury issued final regulations regarding substantiation requirements for cash and noncash charitable contributions. T.D. 9836 (2018). The final Regulations reflect amendments to Section 170 of the...more

Coblentz Patch Duffy & Bass

Happy New Year’s Tidings for Land Trusts and Other Conservation Advocates

The Department of Justice has finally filed a civil complaint against certain promoters who have been spearheading syndicated easements to the tune of over $2 billion in claimed federal tax deductions using grossly inflated...more

Foster Garvey PC

The Seventh Circuit Affirmed the U.S. Tax Court in Exelon Corporation v. Commissioner – Having Expert Tax Advisors on Your Team...

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In Exelon, the Seventh Circuit held that exchanges by Exelon Corporation (“Taxpayer”) of nuclear power plants for long-term leasehold interests in power plants located in other states were not exchanges qualifying for...more

Coblentz Patch Duffy & Bass

IRS Publishes New Gift Substantiation Regulations

Last month, the IRS issued final regulations entitled “Substantiation and Reporting Requirements for Cash and Noncash Charitable Contribution Deductions,” codified as Treasury Regulation Sections 1.170A-15 (cash), -16...more

Proskauer Rose LLP

Wealth Management Update - May 2017

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May Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The May § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs...more

Dickinson Wright

Substantiation of Charitable Donations

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As we enter the giving season and begin making charitable contributions it is important to remember that some gifts require more than just the act of giving to qualify for a charitable tax deduction. For monetary...more

Benesch

Perspectives - August/September 2016

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We’ve all heard about India’s rape crisis, but not everyone knows that it’s the result of the larger problem of gender inequality. According to UNICEF, India is the worst place to be born a girl. The birth of a baby girl is...more

Coblentz Patch Duffy & Bass

Conserve Your Land, Preserve Your Estate: The Conservation Easement as a Land Use, Tax & Estate Planning Tool

We have all been told at one point or another that we simply “can’t have it all.” But for owners of recreational or agricultural land who desire to preserve the land, pass it down to their descendants as a legacy property,...more

Proskauer Rose LLP

Wealth Management Update - March 2016

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March Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The March § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and...more

Balch & Bingham LLP

Conservation Easements FTW! Or, Eagles 1; IRS 0

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What’s a real estate developer to do when its pristine development site, with beautiful ocean views and room for between 164 and 410 upscale residential units that *NEED NOT BE BUILT, is clogged with wildlife, including bald...more

Adler Pollock & Sheehan P.C.

Estate planning for personal property: Why you should sweat the small stuff

When planning their estates, most people focus on major assets, such as business interests, real estate, investments and retirement plans. But it’s also important to “sweat the small stuff” — tangible personal property. This...more

BakerHostetler

Tax Court Rules that IRS Too Aggressive in Applying Qualified Appraisal and Qualified Appraiser Standards

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In Friedberg v. Comm’r, T.C. Memo 2011-238, the Tax Court granted summary judgment for the IRS, holding that an appraisal used to substantiate a facade easement donation amount was not a qualified appraisal because it...more

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