News & Analysis as of

Conservation Tax Credit

Burr & Forman

Conservation Easements: Building Envelopes Doom Donation

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The Tax Court recently issued a full T.C. opinion which will impact a tremendous number of conservation easement donations. In Pine Mountain Preserve, LLLP v. Commissioner, 151 T.C. 4 (2018) the Tax Court found a reservation...more

Coblentz Patch Duffy & Bass

Tax Court Upholds Amendment Clauses But Continues Attack On Floating Homesites In Conservation Easements

When the Tax Court issued its opinion in Pine Mountain Preserve, LLLP v. Commissioner of Internal Revenue, 151 T.C. 14 (December 27, 2018), the conservation community gave a collective sigh of relief because the court...more

Coblentz Patch Duffy & Bass

Tax Court Declines to Follow First Circuit Ruling on Mortgage Subordinations & Conservation Easements

This month, the Tax Court revived a method to defeat conservation deductions with its October 10 opinion published as Palmolive Building Investors LLC et al. v. Commissioner, No. 23444-14; 149 T.C. No. 18 (Oct. 10, 2017),...more

Miles & Stockbridge P.C.

Fourth Circuit Finds Disguised Sale of VA Land Conservation Tax Credits

In Route 231, LLC v. Commissioner, 117 AFTR 2d 2016-XXXX (4th Cir. 2016), the U.S. Court of Appeals for the Fourth Circuit held that certain funds received by the taxpayer constituted income from the sale of Virginia land...more

Burr & Forman

Georgia General Assembly Ends Water and Land Conservation Tax Credits

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At the end of its recent session, the Georgia General Assembly passed HB 464 by unanimous votes to cap the land conservation tax credit at $30 million for 2016 and then eliminate it altogether at the end of 2016. ...more

Williams Mullen

U.S. Tax Court Ruling in State Conservation Tax Credit Case Requires Income Recognition

Williams Mullen on

In its recently issued opinion in the case of Route 231, LLC v. Commissioner, T.C. Memo 2014-30 (2/24/14), the United States Tax Court (the “Court”) held that a transfer of state tax credits to a 1% member who had contributed...more

Saul Ewing Arnstein & Lehr LLP

Fiscal Cliff Deal Preserves Enhanced Conservation Easement Tax Benefits

Conservation easements are an effective tool for tax and estate planning and there are significant tax benefits to implementing them in 2013....more

Burr & Forman

Georgia Department of Revenue Proposes Conservation Tax Credit Rule Changes

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The Georgia Department of Revenue Income is proposing a change to the Tax Division Rule on conservation tax credits. Interested parties seeking to comment on the proposed Rule should review the notice for further guidance....more

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