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
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
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
3/7/2024
/ Appraisal ,
Charitable Donations ,
Conservation Easements ,
Fair Market Value ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Tax Court ,
Tax Deductions ,
Tax Fraud ,
Tax Liability ,
Tax Planning
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
9/27/2023
/ Acquittals ,
Charitable Donations ,
Conservation Easements ,
Criminal Convictions ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Fair Market Value ,
Investment ,
IRS ,
Jury Verdicts ,
Real Estate Market ,
Tax Avoidance ,
Tax Deductions ,
Tax Liability ,
Tax Planning
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
1/12/2023
/ Charitable Donations ,
Conservation Easements ,
Federal Budget ,
Internal Revenue Code (IRC) ,
IRS ,
Pass-Through Entities ,
Regulatory Reform ,
Tax Deductions ,
Tax Liability ,
Tax Planning ,
Tax Reform
On November 9, 2022, in a 15-2 decision, the Tax Court held that the IRS improperly issued Notice 2017-10 in Green Valley Investors, LLC, et al. v. Commissioner of Internal Revenue, 159 T.C. No. 5. The Notice designated...more
11/16/2022
/ Administrative Procedure Act ,
Charitable Deductions ,
Conservation Easements ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment ,
IRS ,
Partnerships ,
Tax Avoidance ,
Tax Court ,
Tax Deductions ,
Tax Penalties ,
Tax Planning
As the IRS and the Department of Justice continue to focus enforcement efforts on conservation easements, the Supreme Court has been asked to settle a dispute regarding the validity of the “protected in perpetuity”...more
On August 7, 2022, the Senate passed the Inflation Reduction Act of 2022 (H.R. 5376) (the “Act”). The announced goal of the Act is to create an economic initiative to address various climate protection initiatives. In...more
8/12/2022
/ Biden Administration ,
Corporate Taxes ,
Excise Tax ,
Federal Funding ,
Internal Revenue Code (IRC) ,
IRS ,
Pending Legislation ,
Regulatory Agenda ,
Tax Credits ,
Tax Deductions ,
Tax Reform
Overview -
Over the past year, several tax law changes have been proposed by the Biden administration and, in September 2021, draft legislative language was circulated, which set forth proposed changes to the Internal...more
12/1/2021
/ Biden Administration ,
Capital Gains Tax ,
Corporate Taxes ,
Foreign Derived Intangible Income (FDII) ,
Foreign Tax Credits ,
GILTI tax ,
High Net-Worth ,
Income Taxes ,
Net Investment Income ,
Pending Legislation ,
SALT ,
Share Buybacks ,
Tax Deductions ,
Tax Liability ,
Tax Planning ,
Tax Reform ,
Wash Sale Rules
In April 2021, President Biden announced the “American Families Plan,” which included some significant tax law changes. On May 28, 2021, the United State Department of Treasury issued a report entitled “General Explanation of...more
9/22/2021
/ Biden Administration ,
C-Corporation ,
Capital Gains Tax ,
Carried Interest Tax Rates ,
Corporate Taxes ,
High Net-Worth ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Like Kind Exchanges ,
Proposed Legislation ,
Tax Deductions ,
Tax Planning ,
Tax Reform ,
Ways and Means Committee
On December 22, 2017, President Trump signed into law what’s known as the Tax Cuts and Jobs Act. The Act, also sometimes referred to as H.R. 1, contains massive changes to existing tax law the likes of which have not been...more
12/28/2017
/ Alternative Minimum Tax ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
New Legislation ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Exemptions ,
Tax Rates ,
Tax Reform ,
Trump Administration
The Senate passed a version of the Tax Cuts and Jobs Act that differs significantly from the House-passed bill but still contains several similar proposals that lower individual and business tax rates, completely revamp the...more
12/5/2017
/ Alternative Minimum Tax ,
Business Taxes ,
Corporate Taxes ,
Income Taxes ,
International Tax Issues ,
Legislative Agendas ,
Net Operating Losses ,
Pass-Through Entities ,
Proposed Legislation ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
The Senate Finance Committee Chairman’s Mark for the “Tax Cuts and Jobs Act,” released Nov. 9, describes in detail the Senate tax bill and is significantly different than the House bill, as it currently stands....more
11/14/2017
/ Alternative Minimum Tax ,
Business Taxes ,
Corporate Taxes ,
Estate Tax ,
Income Taxes ,
International Tax Issues ,
Legislative Agendas ,
Mortgage Interest ,
Pass-Through Entities ,
Proposed Legislation ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
On November 2, 2017, the House Ways and Means Committee released the “Tax Cuts and Jobs Act” (H.R. 1). Key elements include reducing the tax rate on corporations to 20%, and reducing the tax rate paid on income earned by...more
11/3/2017
/ 401k ,
Alternative Minimum Tax ,
Business Taxes ,
Charitable Donations ,
Child Tax Credit ,
Contribution Limits ,
Corporate Taxes ,
Employee Benefits ,
Estate Tax ,
Income Taxes ,
Local Taxes ,
Mortgage Interest ,
Pass-Through Entities ,
Retirement Plan ,
State and Local Government ,
State Taxes ,
Tax Deductions ,
Tax Rates ,
Tax Reform ,
Trump Administration
Comprehensive tax reform that lowers business and individual tax rates, streamlines the tax code, and allows U.S. businesses to become more competitive in the global economy are among the top priorities of the Trump...more
In this issue, we address important new Missouri tax changes that were passed on May 6, 2014 after the Missouri Legislature overruled Governor Jay Nixon's veto. The legislation modifies the individual income tax rate table by...more