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
After much anticipation, the IRS has finally announced a strategic operating plan to spend the nearly $80 billion in funds that it was allocated through the Inflation Reduction Act. Since this bill was signed, the new IRS...more
4/18/2023
/ Enforcement Actions ,
Federal Taxes ,
High Net-Worth ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
IRS ,
Pass-Through Entities ,
Tax Audits ,
Tax Liability ,
Tax Planning ,
Tax Returns
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 October 19, 2022, the Internal Revenue Service (“Service”) issued news release IR-2022-183, which was intended to warn employers using third-party promoters of Employee Retention Tax Credits (“ERTCs”). ERTCs were created...more
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
In April 2021, President Biden announced the “American Families Plan,” which included some significant tax law changes. Among the proposed changes included in the “American Families Plan” was the increase of the tax rate that...more
6/8/2021
/ Biden Administration ,
C-Corporation ,
Capital Gains Tax ,
Estate Planning ,
Internal Revenue Code (IRC) ,
IRS ,
Legislative Agendas ,
Like Kind Exchanges ,
Real Estate Transactions ,
Section 1031 Exchange ,
Tax Deferral ,
Tax Planning ,
Tax Rates ,
Tax Reform
On April 28, 2021, the White House issued a fact sheet which set forth some additional details on the tax increase proposals contained in President Biden’s “American Families Plan.” ...more
This update to our Tax Alert on Nov. 2nd describes additional key provisions in the “Tax Cuts and Jobs Act” (H.R. 1), released by the Chairman of the House Ways and Means Committee on Nov. 2nd, as well as the Chairman’s...more
11/8/2017
/ Compensation & Benefits ,
Deferred Compensation ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Legislative Agendas ,
Repeal ,
Section 409A ,
Tax Code ,
Tax Planning ,
Tax Reform ,
Trump Administration